Privacy Policy for Digital Lending Products

I. Types of Information We collect

We strictly limit our collection of Personal Data to information that is relevant, necessary, and proportionate to the purposes for which it is collected and processed, in accordance with applicable law.

We may collect Personal Data for the purpose of providing Services on the Platform. The categories of Personal Data collected are indicative in nature and may vary depending on the specific digital lending product availed by You, the requirements of the relevant lending partner, and applicable legal or regulatory obligations. Such Personal Data may include:

• Name
• Contact information (phone numbers, email addresses)
• Residential address
• Financial information
• Employment details
• Credit history and records
• Identity Documents and/or any details provided by You to Us to avail various products/Services from Us.
• Voice recordings of Our conversations with the customer care agent to address Your queries/grievances;
• Opinions provided by You to Us by way of feedback or responses to surveys;
• • All information that may have been voluntarily provided by You in connection with availing the Services on the Platform.
• Information required to be collected or retained for risk assessment, record-keeping, or compliance with applicable laws.

Necessary permission/consent shall be sought for the same at an appropriate stage during the Platform usage at all times.

• We may have one time access to Your camera, microphone, location and mobile device for the purpose of onboarding or KYC requirements of us or our partners with Your explicit consent in accordance with the RBI guidelines as amended from time to time. Unless required for compliance with applicable laws or specifically consented to by You, We shall desist from accessing mobile phone resources like file and media, contact list, call logs, telephony functions, etc.
• Except as required under applicable laws or as may be consented by You in compliance with applicable laws, we shall not collect or store Your biometric data.
• You may browse some web pages on our website without telling Us who You are or revealing any Personal Data about Yourself. However, to create an account on Platform, You must provide Us with certain details required to provide our services.

II. Purpose of obtaining the information:

We may collect and process Your Personal Data for the following purposes:

• To establish Your identity and verify the same;
• To facilitate Your KYC with Our lending partners;
• To monitor, improve, and administer Our Platform;
• To provide correct transaction information to You;
• To design and offer customized products and Services on Our Platform from time to time;
• To send communications, notifications, information regarding the products or Services requested by You, or process queries and applications that You have made on Our Platform;
• To conduct data analysis and undertake research and analytics in order to improve the Services/products provided to You;
• To use Your information in order to comply with country laws and regulations;
• To use Your information in other ways permitted by law (statutory and/or regulatory) to enable You to obtain financial services from third-party having contractual relationships with Us;
• To facilitate the transactions (vide the Services) and to report on these transactions to our lending partners;
• • To facilitate, manage and coordinate grievance redressal and complaint resolution with Our lending partners;
• To check and process Your requirements submitted to Us for products/services and/or instructions or requests received from You in respect of these products/services;
• To share with You updates on changes to the products/services and their terms and conditions including Site/Platform’s terms and conditions;
• To take up or investigate any complaints/claims/disputes and provide grievance redressal;
• To respond to Your queries or feedback submitted by You;
• To carry out credit checks, screenings, or due diligence checks as lawfully required by Us and/or credit bureaus;
To undertake financial/regulatory/management reporting and create and maintain various risk management models;
• To conduct audits and for record-keeping purposes;
• To enable us to provide You with selective offers and promotions, search results etc.;
• To comply with the requirements of applicable laws/regulations and/or court orders/regulatory directives received by Us;
• To create Your login credentials or to manage Your profile on the Platform;
• To help promote a safe service on the Platform and protect the security and integrity of the Platform, the Services and the users;
• To detect, prevent and protect us from any errors, fraud and other criminal or prohibited activity on the Platform;
• To contact You;
• To enforce Our legal rights and contractual obligations;
• To store and retain Your data as required under applicable law and regulatory requirements;
• for any other purpose after obtaining Your explicit and unambiguous consent at the time of collection;

Commission/Brokerage: You understand that Angel One may earn commission / brokerage for facilitating loan transactions. This commission is earned for connecting You with Our partners as an agent of such partnerships.

III. Sharing of data with third parties

Any Personal Data that We have access to shall not be shared without Your consent except as specified below. In various processes / submission of applications / availing of product / service offerings, We shall seek Your explicit consent to use / share Your Personal Data.

In our business and operational processes, We only share the data on a “need-to-know” basis to designated personnel or partners or service providers. Where Personal Data is shared with lending partners, such sharing is limited to the Personal Data necessary for facilitating the relevant lending transaction and is undertaken in accordance with applicable law.

Where Personal Data is shared with service providers or other third parties engaged by Angel One for support services, such sharing is limited to the minimum Personal Data required for the specific purpose for which such service provider is engaged, is undertaken on a need-to-know basis, and is subject to appropriate contractual confidentiality and data protection obligations. Please note that data sharing for statutory / regulatory agencies would not require explicit consent. You hereby agree and consent to us collecting, transferring, and sharing Personal Data to our subsidiaries and group companies, service providers and lending partners/ other third-parties.

We will share Your data with the following entities:

• Lending partners and our third-party partners as listed out in Clause XII below.
  • For enabling the provision of the products/services availed by You;
  • For the purpose of reviewing credit records, facilitation of a loan provision or facility or line of credit, suggesting loan eligibility, and the shared information is used by these partners in accordance with their own privacy policies and applicable laws.

• Competent legal/statutory/regulatory agencies or authorities
  • Where it is directed or required by legal/regulatory/statutory/governmental authorities/judiciary under any applicable laws/regulations or judicial pronouncement though a legally obligated request.
  • We may disclose Your information, without prior notice, if We are under a duty to do so in order to comply with any legal obligation or an order from the government and/or a statutory authority, or in order to enforce or apply Our terms of use or assign such information in the course of corporate divestitures, mergers, or to protect the rights, property, or safety of Us, Our users, or others, and this may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
  • Where it is required to verify, mitigate, or prevent fraud or to manage risk or recover funds in accordance with applicable laws/regulations.

• Service Providers acting on our behalf
  • For enabling the provision of the products/services availed by You, strictly on a "need to know" basis and subject to applicable laws.
  • When You make purchases through our services, we may collect and store information about You to process Your requests and automatically complete forms for future transactions, including (but not limited to) Your phone number, address, email, billing information, and payment preferences. This information may be shared with third parties which assist in processing and fulfilling Your requests, including payment gateway processors, and for providing You with products/services to better serve Your needs and interests. Such sharing shall be in accordance with Your instructions and subject to appropriate confidentiality and security requirements.

• Third-party technology service providers and credit partners - To perform credit checks and credit analysis like Credit Information Companies (Credit Bureaus) or third-party data source providers.

• Group companies - if that helps us with any of the purposes noted above or otherwise in this Digital Lending Privacy Policy.

• Anonymised data with other companies - only after scrubbing all personally identifiable details so it is no longer Personal Data.

We will share Your information under confidentiality obligations with the third parties and restrict the use of the said information by third parties only for the purposes detailed herein.

IV. Storage of your Personal Data

We store, process and retain Your Personal Data only on servers located in India, whether such servers are owned, controlled or operated by Us or by third parties engaged by Us under contractual arrangements.

Angel One does not store Personal Data outside India. Where any limited processing of Personal Data is required to be carried out outside India strictly for technical or operational purposes, such processing shall be undertaken in compliance with applicable law, and the Personal Data shall be deleted from servers outside India and repatriated to servers located in India within the timelines prescribed under applicable regulatory requirements.

We will use and retain the information for:

• for the period that You continue to be our customer; and
• for such period as required to comply with any obligation under any law for the time being in force.
• such periods as necessary to provide You the Services on the Platform, to comply with our legal obligations, to resolve disputes, and enforce the agreements entered into by You and for such other reasons as specified in Clause II above;

We will comply with the procedure for destruction and disposal of Your Personal Data.

V. Cookie Policy

We may also collect certain non-personal information, such as system generated user ID and access tokens (“Non - Personal Information”) while You browse, access or use the Platform or if You have Our mobile application on Your device. We receive Non–Personal Information by the use of data collection devices such as “cookies” on certain pages of the Platform, in order to help and analyse our web - page flow, track user trends, and promote trust and safety. We may use cookie and tracking technology depending on the features offered. We may place both permanent and temporary cookies on Your device. We also use cookies to allow You to enter Your password less frequently during a session on the Platform. Most cookies are “session cookies,” meaning that they are automatically deleted from Your hard drive at the end of a session. You are always free to decline our cookies if Your browser permits, although in that case, You may not be able to use certain features or Services being provided on the Platform or You may be required to re-enter Your password each time You log – in or access the Platform during a session. No Personal Data will be collected via cookies and other tracking technology; however, if You previously provided Personal Data, cookies may be tied to such information.

VI. Links to other websites

Our Platform may provide links to other third - party platforms including those of third-party Partners (“Third – Party Sites”) that may collect Your Personal Data such as Your IP address, browser specification, or operating system, etc. We are not in any manner responsible for the security of such information or their privacy practices or content of those Third – Party Sites. Additionally, You may also encounter “cookies” or other similar devices on certain pages of the Third – Party Sites and it is hereby clarified by the Company and its Affiliates that they do not control the use of cookies by these Third-Party Sites. These third-party service providers and Third-Party Sites may have their own privacy policies governing the storage and retention of Your information that You may be subject to. We are not liable for the information published in search results or by any Third-Party Sites.

VII. Reasonable Security Practices and Procedures

We use several security techniques to safeguard your data including secure servers, firewalls and encryptions. We have in place appropriate administrative, technical, physical safeguards and security measures to protect the Personal Data You provide to us against accidental, unauthorized or unlawful loss, destruction, damage, alteration, access, disclosure or use and any other unlawful forms of processing. We shall also ensure compliance with various technology standards/requirements on cybersecurity stipulated under applicable laws in provision of Our Services to You.

Such safeguards include measures such as role-based access controls, restriction of access to Personal Data on a need-to-know basis, secure transmission of data, monitoring and logging of system activity, segregation of environments, and periodic review of security controls. We also take reasonable steps to ensure that third parties engaged by us for processing Personal Data implement security measures that are commensurate with the sensitivity of the data and the nature of the processing undertaken.

We cannot however ensure or warrant the security of any information You transmit to Us or guarantee that Your Personal Data may not be accessed, disclosed, altered, or destroyed by a breach of any of our security measures and safeguards. In the event of any actual or suspected security incident, including data breach, we will take all measures required to be undertaken under applicable laws.

It is further clarified that You have and so long as You access and/or use the Platform (directly or indirectly) the obligation to ensure that you take adequate physical, managerial, and technical safeguards at your end to preserve the integrity and security of your information including Your Personal Data. In case of non-compliance and/or breach with this Digital Lending Privacy Policy pertaining to access or usage of the computer resource, We shall have the right to terminate the access or usage rights of Yours to the computer resource immediately or remove non-compliant information or both, as the case may be.

VIII. Contact us

You may choose: (i) not to provide the information, specific data requisitioned by Us from You in connection with Our Services from time to time or (ii) to withdraw Your consent granted to collect Your Personal Data. In these cases, We reserve the right to prevent You from accessing the Platform and to not provide You any Services through the Platform. In such a scenario, the Company may delete Your information (Personal or otherwise) or de-identify it so that it is anonymous and not attributable to You.

We shall delete Your Personal Data upon Your request, provided there is no active loan or service being availed by You or unless Your Personal Data is required to be retained due to applicable laws or any regulatory requirement. You may send an email to lendingsupport@angelbroking.com for any such request. The email should mention Your mobile number, lender name, and type of modification required along with request for data deletion. The data deletion will happen within 45 days of Your request.

If You have any queries, feedback, questions, or concerns regarding the collection, processing, usage, disclosure, and security of Your information/data, or any aspect of this Digital Lending Privacy Policy, please address them to lendingsupport@angelbroking.com.

IX. Policy Review & Updates

This Digital Lending Privacy Policy shall apply uniformly to Our desktop website, mobile site and mobile applications. This Digital Lending Privacy Policy is subject to change at any point in time. We reserve the right to change/modify the information provided on or via this Site/Platform, including the terms of this disclaimer, at any time and without notice.

You can determine when the Terms were last modified by referring to the “Last Updated” legend above. We shall not undertake to update You with the content contained on this Site/Platform from time to time and we recommend that You review this Digital Lending Privacy Policy periodically.

You are obliged to exercise Your independent diligence on the information provided on or via this Site/Platform before arriving at any decision and You will be solely responsible for Your actions. We shall not be held responsible for all or any actions that may subsequently result in any loss, damage and or liability on account of such change in the information on this Site/Platform. Your continued use of the website/mobile application following the posting of changes shall mean that You accept and agree to the changes and shall be legally bound by the same.

X. Grievance Redressal

For grievances related to Our Platform, You can reach out to Our nodal officer(s) at:

Name: Gable Fernandes

Email id:lendingsupport@angelbroking.com

Phone No: 8655731284

Toll Free No: 1800 1020

Designation: Nodal Grievance Redressal Officer

Address:601 6th Floor, Ackruti Star, Central Road - MIDC, Andheri (E), Mumbai - 400 093 

You may also reach out to Our lending partners for any grievances related to Your loans. The details of the grievance officers of our lending partners can be found below:

Lender Name: KSF

Name: Mr. Emaad Khan

Phone: +91 99620 03070

Email Id:grievance@creditsaison-in.com, https://creditsaison.in/partnercontact

Grievance Redressal mechanism: Kisetsu Saison Finance India Private Limited (Credit Saison)

Lender Name: SMFG

Name: Ritesh Saxena

Email Id - GRO@smfgindia.com

Number - 022-69581104

Designation: Grievance Redressal Officer

Grievance Redressal mechanism: SMFG India Credit Co. Ltd.

Lender Name: Aditya Birla Capital Limited

Name: Mr. Arijit Sen

Designation: Grievance Redressal Office

Email: grievance.finance@adityabirlacapital.com

Number: 080 – 45860196

Grievance Redressal mechanism: Aditya Birla Finance Ltd.

Lender Name: IDFC FIRST Bank

Name: Mr. Vipul Raj (Principal Nodal Officer)

Email: pno@idfcfirstbank.com

Number: 1800 209 9771

Grievance Redressal mechanism: IDFC FIRST Bank

Lender Name: Axis Bank

Name: Mr. Ashish Rajput (Assistant Vice President)

Email: nodal.officer@axisbank.com

Number: 08061865200

Grievance Redressal mechanism: Axis Bank

Lender Name: KrazyBee Services Private Limited

Name: Mr. Sauraw Kumar (Grievance Redressal Officer)

Email: reachus@kbnbfc.in

Number: 8044292555 / 8068534555

Grievance Redressal mechanism: KreditBee

Lender Name: Poonawalla Fincorp

Name: Mr. Arnab Das (Principal Nodal Officer)

Email: pno@poonawallafincorp.com

Number: 020-67808090 / 020-67808090

Grievance Redressal mechanism: Poonawalla Fincorp

Lender Name: Finnable Technologies Private Limited

Name: Akshay N Raja (Grievance Redressal Officer)

Email: gro@finnable.com

Number: 9741160321

Grievance Redressal mechanism: Finnable

If the complaint has not been addressed by the respective lending partner within 30 days from the date of raising the complaint or the provided response is not satisfactory, the customer can lodge a complaint over the Complaint Management System (CMS) portal (https://cms.rbi.org.in/cms/indexpage.html#eng) under the Reserve Bank-Integrated Ombudsman Scheme (RB-IOS) or send a physical complaint to “Centralised Receipt and Processing Centre, 4th Floor, Reserve Bank of India, Sector-17, Central Vista, Chandigarh - 160017” as per the grievance redressal mechanism prescribed by the Reserve Bank. This information shall be suitably conveyed to the borrower. For banks / lending partners currently not covered under RB-IOS, complaint may be lodged as per the grievance redressal mechanism prescribed by RBI.

XI. Governing Law & Jurisdiction

This policy will be governed by and construed in accordance with the laws of India and subjected to the exclusive jurisdiction of Courts of Mumbai.

XII. Details of associated third parties

Name	Services Provided
Kisetsu Saison Finance (India) Private Limited	Lending Partner
Acko General Insurance Limited	Insurance Partner
Digiotech Solutions Private Limited	Nach Mandate
Hyperverge Technologies Private Limited	Support Services
Moshpit Technologies Private Limited (Finbox)	Support Services
Experian Credit Information Company of India Private Limited	Credit Information Partner
SMFG India Credit Co. Ltd.	Lending Partner
Aditya Birla Finance Limited	Lending Partner
IDFC First Bank	Lending Partner
Axis Bank	Lending Partner
KrazyBee Services Private Limited	Lending Partner
Poonawalla Fincorp	Lending Partner
Finnable Technologies Private Limited	Loan Platform Partner
Fifty Fintech Private Limited	Loan Platform Partner