This document (“Privacy Policy”) is published by virtue of the legal requirement under the provisions of the Information Technology Act, 2000 and RBI Guidelines on Digital Lending dated Sep 02, 2022 that require to publish the rules and regulations, privacy policy and terms for access or usage of their Mobile Application/mobile app and is primarily governed by Rule 3 (1) of the Information Technology (Intermediaries Guidelines) Rules, 2011 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.
Commitment
PAHAL intends to protect the privacy of its users and members on its app and the privacy of the data provided by them to PAHAL from time to time. For the purpose of this Privacy Policy, mobile application means and includes mobile application (PAHAL Instant Personal Loans) of PAHAL.
The privacy of our mobile application users, whether you are our former or existing registered user or merely a visitor to our mobile application, is important to us and we are strongly committed to your right to privacy and to keeping your personal and other information secure. We encourage you to read our privacy statement to understand what types of personally identifiable information we collect and how we use this information.
What type of information does PAHAL collect from you?
Personal Information
For the purpose of providing, you our services, we require you to enrol yourself on our Mobile application and get yourself registered.
INFORMATION COLLECTED THROUGH MOBILE APPLICATIONS
PAHAL services are also provided through the Mobile Application. The information collected through Mobile Applications is as mentioned below:
How do we use this information: We use this information to facilitate the provision of software updates, product support and other ancillary services.
How do we use this information: We use this information for identifying and resolving any technical glitches that may be identified from such data and also for improving the overall functionality of the Application.
How do we use this information: We use SMS information for (i) carrying out your credit assessment (ii) facilitating your loan application journey (iii) improving your app experience through customized loan terms and personalized assistance while onboarding.
How do we use this information: We may use your device location information for verifying your address, for the KYC and onboarding process for the services. We may also request camera access to scan and capture the required KYC documents. We may request for microphone and audio permissions to enable a two-way communication between the authorised agents and you for the purpose of performing and completing your KYC. Your audio may be recorded for regulatory purpose. Device Storage Permission may be requested so that you can download and save the documents on your phones and upload the right documents including images for KYC, business registration documents verification etc. for faster approval and disbursal of the loan.
Non-Personal Information
PAHAL also collects certain other information from you on your visit to our Mobile Application such as information about your operating system, browser type, the URL of the previous Mobile Application 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 Mobile Application, analyze trends in the market, gather demographic information, to ascertain how our visitors use our Mobile Application, including information relating to the frequency of visits to our Mobile Application, 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 Mobile Application content and performance. You also agree that PAHAL may gather usage statistics and usage data from your use of our Mobile Application to evaluate your use of our products/services, to improve our products/services, Mobile Application content and to ensure that you are complying with the terms of the applicable agreements between you and PAHAL. The statistics and data collected may or may not be aggregated. These statistics contain no information that can distinctly identify you.
We may in future also share this information with third party service providers or third party advertisers to measure the overall effectiveness of our online advertising, content, programming and for other bonafide purpose, as we may desire. By usage of our Mobile Application you expressly permit PAHAL to access such information for one or more purposes deemed fit by PAHAL.
Cookies
Similar to other commercial web sites, our Mobile Application utilizes standard technology called “Cookies” and Web server logs to collect information about how our Mobile Application 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 Mobile Application including the date and time of visits, the pages viewed, time spent at our Mobile Application, and the Mobile Applications visited just before and just after our Mobile Application, 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. PAHAL understands and supports your right to block any unwanted Internet activity, especially that of unscrupulous Mobile Applications. However, blocking PAHAL cookies may disable certain features on our Mobile Application and may make it impossible for you to use certain services available on our Mobile Application.
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 Mobile Application. 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 analyse things such as the items visitors are likely to click on most, the manner in which visitors click preferences on our Mobile Application, number of visitors surfing to various pages on the Mobile Application, time spent by the visitors on our Mobile Application 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.
Sharing of Information
PAHAL may share your Information, including the bureau reports, with its service providers, affiliate(s), agents, partners and such other third parties, in accordance with applicable laws, for the purposes of (i) providing the services and to perform the functions on your behalf or on behalf of PAHAL; (ii) marketing new products and services by PAHAL or by any of its affiliate(s), service partners and third parties; or (iii) marketing of services provided by such third parties, affiliates and service partners of PAHAL or (iv) to intimate you for any new products, services, offers and/or promotions being offered by PAHAL or any of its affiliate(s), third partners or service partners . It is hereby expressly declared that third parties / service partners shall be responsible for use of your Information by them.
Third Party Products and Services
There are services and/or products offered by third parties on the Mobile Application. If you choose to apply for these third-party products and/or services, then their use of your Information shall be governed by their privacy policies and PAHAL shall not be responsible for their use of your Information and their privacy policies.
PAHAL shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such external Mobile Application or resource.
Other
We may from time to time add or enhance products/services available on our Mobile Application. To the extent these products/services are provided to and used by you, we will use the information you provide in this regard to facilitate the products/service requested. For example, if you email us with a question, we will use your email address, name, nature of the question, etc. to respond to your question. We may also store and publish such information to assist us in making the Mobile Application better and easier to use.
PAHAL’s use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
Promotional Initiatives
PAHAL may have presence on social networking Mobile Applications including but not limited to LinkedIn, Facebook, Twitter, YouTube, and blogs which are promotional and business initiatives to connect to a larger group of people. The domain links contained therein may either direct you to our Mobile Application or request your participation by way of feedback, suggestions. PAHAL in this regard fully disclaims any liability (ies) or claim(s), which may arise by use/misuse of your feedback, suggestions, views, etc. on any of the aforementioned networking Mobile Applications or blogs, by any third party whether or not known to PAHAL.
Links to Other Sites
Our Mobile Application may contain links to other Mobile Applications. If you click on a third-party link, you will be directed to that Mobile Application. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the privacy policy of these Mobile Applications. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
Does PAHAL protect my Personal Information?
PAHAL is committed to protecting the privacy and the confidentiality of your Personal Information. Whenever PAHAL obtains Information from you, our Mobile Application uses commercially reasonable efforts and general industry standards to protect it from any unauthorized access or disclosure. PAHAL ensures that your Information is stored in a safe and secure manner, as per applicable laws. PAHAL uses its best endeavours to maintain physical, electronic and procedural safeguards that aim to protect your information against loss, misuse, damage, modification, and unauthorized access or disclosure. Any disclosure of Information to any third party(ies) and/ or service partners for providing any services to you by such third parties and/ or service partners, shall be in accordance with applicable laws and the terms of this Privacy Policy. It is hereby expressly declared that third parties / service partners shall be responsible for use of your Information by them.
How does PAHAL use the information that it collects?
Information shared by you is used by us and/or authorized third parties/service partners/affiliate(s) to support your interaction with us, to offer you services in the best possible manner and to contact you again about other services and products that we and/or authorized third parties/service partners/affiliate(s) offer. By submitting your Information to PAHAL, you expressly acknowledge and consent to PAHAL to use such Information and to process the same in a manner deemed fit by PAHAL and provided in this Privacy Policy, in compliance with applicable laws. This may involve conducting data analysis, research based on reviews about deals, transfer of your Information to third party experts for the purpose of outsourcing services offered to you by PAHAL, transfer your Information to third parties/ service partners for providing you services offered by such third parties and service partners etc.
Below is the link of all the third parties / service partners/affiliate(s) used by PAHAL, who will collect, store, transfer, and process your Information required for business operation. The list of third parties / service partners/affiliate(s) shall be updated by PAHAL from time to time, for your reference.
What security precautions are in place to protect against the loss, misuse, or alteration of your information?
PAHAL makes every reasonable effort to preserve the privacy and confidentiality of your information shared with us. We implement standard measures to protect against unauthorized access to and unlawful interception of Personal Information. However, no Internet Mobile Application can fully eliminate security risks. PAHAL implements cyber security policy and technology standards as stipulated by RBI and other agencies as may be specified time to time for handling all security breaches in compliance with applicable laws and regulations.
We reserve the right to disclose Information shared by you as required or permitted under applicable law and we have a good-faith belief that (i) such action is necessary to comply with an appropriate law enforcement investigation, current judicial proceeding, a court order or legal process served on us or (ii) to conform to the legal requirements, compliance/reporting to administrative and judicial authorities, as may be required (iii) protect and defend the rights or property of the Mobile Application owners of PAHAL, or the users of PAHAL, Further, we reserve the right to disclose Information shared by you with credit information companies (CICs).
What is PAHAL policy on retention and destruction of information that it collects?
PAHAL has defined a record retention period for your Information as five (05) years from the date of last processing of your Information. All deletion of Information will happen within a reasonable period {no later than ninety (90) days} after expiry of the retention period. All physical data will be disposed by shredding or otherwise making unreadable confidential records in accordance with applicable laws. All electronic data will be disposed in a responsible manner and in compliance with applicable laws with prior approval from PAHAL’s CTO/CISO.
“The extent of instructions on record management as stipulated in the Master Directions/Directions/Guidelines/Guidance issued by Reserve Bank of India, with reference to provisions of Prevention of Money Laundering (Maintenance of Records) Rule, 2005 (PML Rule, 2005) from time to time would be the directing force.”
I have more questions about privacy policy
If you have any questions about this Privacy Policy, the practices of this Mobile Application, or your dealings with this Mobile Application, please contact us at ho@pahalfinance.com
Will PAHAL change privacy policy in the future?
This policy provides a general statement of the ways in which PAHAL aims to protect your information. You may, however, in connection with specific products or services offered by PAHAL, be provided with privacy policies or statements that substitute or supplement this policy. The terms and conditions of this Privacy Policy may be updated, if required under applicable laws and shall be made available on the Mobile Application. The revised Privacy Policy will be effective immediately upon posting to our Mobile Application unless otherwise mentioned. This version of the Privacy Policy is effective from June 2024. The revised Privacy Policy shall bind you and it is your sole responsibility to check the same from time to time. You acknowledge that no knowledge of the revised Privacy Policy shall not be a defence in any proceedings with regard to the Privacy Policy.
Your Consent
By accessing our Mobile Application and using it on a continued basis, you expressly consent and confirm to PAHAL collecting, maintaining, using, processing and disclosing your Personal Information and other information in accordance with this Privacy Policy. You may reach out to PAHAL on email CGRM@pahalfinance.com if you wish to revoke the consent provided here including deletion of your Personal Information and PAHAL shall ensure the same. However, once you are onboarded, Information which needs to be stored and/or shared with third parties / service partners /affiliate(s) as per regulatory and statutory requirements will be retained by PAHAL. Any other data which is not mandatory to be stored and / or transferred will be deleted on your request.
I have a complaint/concern
In accordance with the relevant provisions of the Information Technology Act, 2000 and Rules and RBI Guidelines on Digital Lending dated Sep 02, 2022, made thereunder, the name and contact details of the Grievance Officer who can be contacted with respect to any complaints or concerns including those pertaining to breach of Pahal’s Terms of Use, Privacy Policy and other polices or questions are published as under:
If the Borrower does not receive a response from the Grievance Redressal Officer within 30 (thirty) days of making a representation, or if the Borrower is not satisfied with the response received from the Grievance Redressal Officer/Nodal Officer, the Borrower can lodge a complaint over the Complaint Management System (CMS) portal under the Reserve Bank-Integrated Ombudsman Scheme (RB-IOS).
Grievance Redressal Officer: Ms. Nisha Dwivedi
Email ID: : CGRM@pahalfinance.com
Contact Number: 027-17479169
The Grievance Officer can be contacted between 10:30 a.m. to 6:30 p.m. from Monday to Saturday except on public holidays.
