This privacy policy (“Policy“) has been drafted in accordance with the Information Technology Act, 2000, the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011, Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 to the extent applicable, and applicable RBI guidelines and regulations.

MAKSPay Fintech Solutions Private Limited (hereinafter “PehchanPe”,“Us”, “Our”, “We”, which shall mean and include its affiliates, successors and assigns) owns and operates mobile application under the brand name of PehchanPe and website, www.makspay.com, under the brand name(collectively referred to as “Platform”).

THIS POLICY DESCRIBES OUR POLICIES AND PROCEDURES FOR COLLECTION, USE, STORAGE, PROCESSING, DISCLOSURE AND PROTECTION OF ANY INFORMATION, INCLUDING, BUT NOT LIMITED TO, PERSONAL INFORMATION PROVIDED BY YOU AS A USER (HEREINAFTER REFERRED TO AS “YOU”, “YOUR” or “USER”) WHILE USING THE PLATFORM AND YOUR PRIVACY RIGHTS. USER SHALL MEAN ANY PERSON/ PERSONS, WHO VISITS, USES, DEALS WITH AND/ OR TRANSACTS THROUGH THE PLATFORM.

THIS POLICY CONSTITUTES A LEGAL AGREEMENT BETWEEN YOU, AS THE USER OF THE PLATFORM, AND PEHCHANPE, AS THE OWNER OF THE PLATFORM.

YOU MUST BE A NATURAL PERSON, CITIZEN OF INDIA WHO IS ATLEAST 18 YEARS OF AGE AND ELIGIBLE TO ENTER INTO A BINDING CONTRACT UNDER THE INDIAN CONTRACT ACT, 1872.

BY VISITING/ ACCESSING THE PLATFORM AND VOLUNTARILY PROVIDING US WITH INFORMATION, YOU ARE CONSENTING TO OUR USE OF YOUR INFORMATION IN ACCORDANCE WITH THIS POLICY.

THIS POLICY SUPERSEDES ANY PREVIOUS COMMUNICATION ON THIS SUBJECT MATTER AND DOES NOT APPLY TO THIRD-PARTY WEBSITES AND APPLICATIONS THAT ARE CONNECTED VIA LINKS TO THE PLATFORM. YOU ACCESS THIRD-PARTY APPLICATIONS AND WEBSITES AT YOUR OWN RISK AND WE ARE NOT LIABLE OR RESPONSIBLE TO YOU FOR ANY THIRD-PARTY APPLICATIONS AND WEBSITES.

IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, PLEASE DO NOT PROCEED FURTHER TO USE/ ACCESS THIS PLATFORM.

THIS POLICY IS A PART OF THE TERMS OF USE LOCATED HERE. YOUR USE OF THE PLATFORM WILL BE GOVERNED BY THIS POLICY TOGETHER WITH ALL POLICIES, NOTICES, GUIDELINES, DISCLAIMERS THAT ARE PUBLISHED ON THE PLATFORM AND/OR SHARED WITH YOU FROM TIME TO TIME AND SUCH OTHER TERMS AS MAY BE APPLICABLE TO YOU AS A USER OF THE PLATFORM.

WE MAY UPDATE THIS POLICY FROM TIME TO TIME. WE SHALL INFORM YOU AT LEAST ONCE IN A YEAR OF OUR PRIVACY POLICY FOR YOU TO TAKE NOTE OF ANY CHANGES IN THIS PRIVACY POLICY IF YOU ARE A REGULAR USER OF OUR PLATFORM. HOWEVER, WE URGE YOU TO PERIODICALLY REVIEW THE POLICY FOR THE LATEST INFORMATION ON OUR PRIVACY PRACTICES. CHANGES AND MODIFICATIONS TO THIS POLICY WILL TAKE EFFECT IMMEDIATELY UPON POSTING ON THE PLATFORM. ANY CONTINUED USE OF THE SERVICES SHALL SIGNIFY YOUR ACCEPTANCE OF SUCH UPDATED POLICY.

Services

We collect information to provide services (“Services”) to You in the nature of:

A. Facilitating the provision of loans:

We act as a technology and service provider for facilitating the provision of loans to You through Our financial partners such as banks and NBFCs (“Lending Partners”) and provide ancillary services to Our Lending Partners in relation to the loans they provide to You.

Information that We Collect: We collect the following information from You with Your explicit consent per instructions from Lending Partners for processing Your loan application:

1. Name,
2. Mobile number,
3. Gender,
4. PAN number,
5. Personal email id,
6. Work email id,
7. Pin code,
8. Employer name,
9. Father’s / Mother’s / Spouse’s name,
10. Family details,
11. Current residential address,
12. Geo Location LAT/LONG,
13. Office address,
14. Bank account number,
15. Bank statements,
16. Aadhar card,
17. Driver license,
18. Any other KYC documents issued by Government,
19. Income details,
IP address and OS: We collect IP address and OS for fraud check purposes and onboarding, and
Any other information as required by Lending Partners.

We do not access mobile phone resources like file and media, contact list, call logs, telephony functions and others or collect any biometric data. However, we may take a one-time access of Your camera for uploading a selfie image, microphone, location or any other facility for the purpose of KYC and loan onboarding journey.

We may receive information related to Your loan transactions from Our Lending Partners if We are providing ancillary services to the Lending Partner such as collection of outstanding dues with respect to loan product provided to You by Lending Partners or for processing of Your loan application. We may share such information with Our subcontractors who will be using this information to provide services as outsourced to Us by Our Lending Partner.

Sharing of information: We share the aforesaid information with Lending Partners and third parties for authentication through OTP, to contact You regarding any loan product You display interest in or for completing a loan application, KYC check, collection of KYC documents, bank authentication purpose, to perform employment checks, for NACH registrations, and loan repayment purposes.
For details of Our Lending Partners, You may refer to website link of Our Lending Partners which we publish on Our Platform.
Please note that any information collected for loan application processing shall be collected with Your explicit consent, detailing the purpose of collection.

B. Provision of Credit Report:

We fetch Your credit report (“Report”) from credit bureaus such as CIBIL and CRIF as Your agent after obtaining Your explicit consent and authorisation.
Information that We Collect: We collect Your name, gender, email ID, and PAN to establish Your identity for this purpose.
Sharing of Report: This Report is provided to You and is not shared with any third party.

On provision of information as mentioned in this Clause, You provide Your express consent to Us to use the information for the purpose stated in this Clause in accordance with this Policy.

C. Customer support:

You may write to us at support@PehchanPe.com for any customer support in relation to the Services provided by Us.
Information that We Collect: We collect the information that You provide when Your write to Us for support to improve Our Services.
Sharing of information: We share Your information with third parties and Lending Partners to provide effective customer support Services

By writing to us, You provide Your express consent to Us to use the information listed in this Clause for purposes mentioned in this Clause.

D. Cookies

Cookies are small data files that are stored on your device. PehchanPe and third-party service providers/partners may use cookies or similar technologies to analyze trends, understand User’s behaviour, administer the Platform, track Users’ movements around the Platform, and to gather demographic information for providing the User with a tailored and user-friendly services and measure promotional effectiveness. In the event PehchanPe intends to collect cookies, We will take your consent for the same. You may utilise the disable cookies option in the browser if You do not wish to share cookies at any point of time. However, the Services we provide to You may get affected if You do not provide consent for Us to collect cookies.

II. Your rights

With respect to the information collected by Us to provide Services, You have the following rights available to You:

Right to deny:

You may deny consent to provide any information required by Us, restrain Us from sharing information with Lending Partners or third parties (as the case maybe), refuse storage of information or not provide Us the right to contact You.

B. Right to withdraw consent with respect to use of information and right to be forgotten:

You have the right to withdraw consent previously provided to Us with respect to Our usage of Your information and You have the right to require the Platform to delete/ forget the data relating to You. Right to withdraw consent includes consent provided to Us previously for specific use of information, storing of information, sharing Your information with third parties and Lending Partners and consent to contact You.

Basis Your request, We shall purge the information provided by You if there is no legal requirement to retain such information.

However, we reserve the right to retain information to the extent required for below mentioned purposes:

Comply with applicable laws;
Enforce Our legal rights; or
To provide any information required by regulatory authorities investing any fraud or illegal activities.

However, Lending Partner may contact You regarding the loan application and payment of dues and shall continue processing Your information, if Your application for provision of loan was sent to Lending Partner or if You have availed any loan from Our Lending Partner till all dues of loan are paid. The Lending Partner may store Your information for as long as required to be stored per applicable laws. The Lending Partner may also require Us to retain information in circumstances when the Lending Partner has outsourced any services in relation to loan product such as collection of dues to Us and in such cases, We will be required to retain Your information.

C. Right to rectify:

We disclaim all liability and responsibility for the authenticity of the information provided by You to Us. However, You have the right to review and correct, update and/or amend Your information provided to Us previously for it to be accurate, complete and up to date.

However, kindly note that in a situation where You deny consent, withdraw consent, avail the right to be forgotten, or provide inaccurate information, You may not be able to avail the entire scope of our Services, and in such instance, we reserve the right to not provide You access to our Services or any part thereof.

D. How we protect and store Your information

Our security systems and process are compliant with applicable laws. We store and process Your information only in India. Our data centre and systems maintain backup and We have disaster recovery systems in place. Information shared with Us is hosted on virtual private cloud provided by a third party service provider . The virtual private cloud provides a secure and scalable technology platform to ensure We can provide You Services securely and reliably.

We have information security management system framework in place that ensures up-to-date physical security, such as secure areas in offices; electronic safeguards, such as passwords, firewalls, and encryption; and secure development procedures. Access control systems are in place. Our safety and security processes are audited by a third party cyber security audit agency from time to time.

In the scenarios where personal information collection is mandatory, for instance any information required to pull bureau report or for loan application, we encrypt the data with the latest security algorithms before transmitting the data. All such data is encrypted at rest.

Information You and Our Lending Partners provide and receive during the Services is transmitted through a secure sockets layer (SSL) transmission. We encrypt and store personal information wherever it is possible. No data is shared with any third party unless until it is a core feature to serve the end-user, in all such scenarios the user consent is taken.

We restrict access to Your personal information only to those employees who are required to know such information in order to provide Our Services to You. We train Our employees on all Our security procedures, and We conduct audits to check compliance.

No security measures can provide absolute protection of data, but We strive to protect Your information. If You are a security enthusiast and have found a possible security vulnerability on our products, we encourage You to report the issue to Us responsibly. You can reach out to Us at security@PehchanPe.com.

If you choose to use Our social network pages (Facebook Fan page, Twitter, Linkedin, Google Play Store, Apple ITunes store etc), any information You submit can be read, collected, or used by other users of these sites. We are not responsible for the subsequent use of information, which You have submitted to the foregoing sites, by other users.

We retain Your minimal information for as long as it is necessary for providing You the Services available on the Platform or for carrying out Our operations unless We receive Your request for deletion of information. This however excludes, any information required to be retained due to relevance of information to any pending litigation or information that is otherwise required to be retained under any other law for the time being in force or information required to be retained due to instructions from Lending Partner. On receipt of Your request for deletion of information, We will delete Your information in accordance with Clause 3(b).

III. Confidentiality

We may share Your data with third Parties for providing and improving Our Services, enforcing PehchanPe Terms of Use, and may use or assign Your information in the course of corporate divestitures, mergers, or to protect the rights, property, or safety of Us, Our Users, or others. Our third-party partners are under an obligation under the contract executed with Us to maintain confidentiality of Your information and not transfer such information without Our prior consent. Our contracts with these third parties outline the appropriate use and handling of Your Information and prohibit them from using any of Your information for purposes unrelated to the service they are providing. We also take reasonable measures and strive that any third party to whom information is transferred maintains the security standards per applicable laws. However, We are not responsible for any breach of security or for any actions of any third parties that receive Your personal information.

A. Masking of personal data - where the customer submits a proof of possession of Aadhaar card, containing Aadhaar Number, we ensure that we mask or black out his Aadhaar number through appropriate means where the authentication of Aadhaar number is not required as per regulation as per RBI Circular RBI/DBR/2015-16/18 Master Direction DBR.AML.BC.No.81/14.01.001/2015-16. When sharing or using Aadhaar, post authentication, we mask or cover the first eight digits of the Aadhaar number, leaving only the last four digits visible. This helps in preventing the misuse of Aadhaar numbers and protects individuals from identity theft.. Periodic and need basis access review and reconciliation can be done.

IV. Obligation of the User

You hereby agree that You shall not host, display, upload, modify, publish, transmit, store, update or share any information that:

belongs to another person and to which the user does not have any right;
is in violates any law for the time being in force;
deceives or misleads the addressee about the origin of the message or knowingly and intentionally communicates any information which is patently false or misleading in nature but may reasonably be perceived as a fact;
impersonates another person; and
is patently false and untrue, and is written or published in any form, with the intent to mislead or harass a person, entity or agency for financial gain or to cause any injury to any person.

V. Grievance Redressal

If You have any grievance regarding the use of Your information which We collect or this Privacy Policy, You may write to Our Grievance Redressal Officer (“GRO"):

Name: Mrs. Kavitha Palancha
Address: # 101, La Palazzo A Apartments, Software Layout, Srinivas Hills, Madhapur, Hyderabad, TG 500083 IN
E-mail: nodal.officer@PehchanPe.com

If You require any further information or clarification, You may also contact Us at support@PehchanPe.com.

VI. Severability and Exclusion

We have taken every effort to ensure that this Policy adheres with the applicable laws. The invalidity or unenforceability of any part of this Policy shall not prejudice or affect the validity or enforceability of the remainder of this Policy. This Policy does not apply to any information other than the information collected by PehchanPe through the Platform. This Policy shall be inapplicable to any unsolicited information You provide Us through this Platform or through any other means. This includes, but is not limited to, information posted in any public areas of the Platform. All unsolicited information shall be deemed to be non-confidential and PehchanPe is free to use and/ or disclose such unsolicited information without any limitations.

VII. Governing Law and Dispute Resolution

This Policy shall be governed by and construed in accordance with the laws of the Republic of India. The courts at Hyderabad, India shall have exclusive jurisdiction in relation to any disputes arising out of or in connection with this Policy.

VIII. No Waiver

The rights and remedies available under this Policy may be exercised as often as necessary and are cumulative and not exclusive of rights or remedies provided by law. It may be waived only in writing. Delay in exercising or non-exercise of any such right or remedy does not constitute a waiver of that right or remedy, or any other right or remedy.

IX. Applicability of local laws

PehchanPe is a company based in India. By browsing/using the Platform, You hereby acknowledge that PehchanPe is not responsible or liable in any manner to comply with any local laws of Your territory except India.