Privacy Policy

By visiting this Small Credit old mobile and/or web application (“App”) (collectively, the “Platform”) and availing the services provided by us (“Services”) you agree to be bound by the terms and conditions of this Privacy Policy. If you do not agree to this Policy or any part thereof, please do not use or access our Platform or any part thereof.

The Platform recognizes the importance of maintaining your privacy. This Privacy Policy describes how the Platform collects and handles certain information it may collect and/or receive from you. This Privacy Policy applies to current and former visitors to our Platform. By visiting and/or using the Platform, you are accepting and consenting to the practices described in this Privacy Policy.

For the purpose of this Privacy Policy, the users of the Services may be customer/consumers, or any other persons using Services or accessing our Platform (“user” or “you” or “your”).


WHAT PERSONAL INFORMATION ABOUT YOU WE GATHER
The information we learn from customers helps us personalize and continually improve your experience on the platform.
 In general, you can browse the Website or App without telling us who you are or revealing any personal information about yourself. However, to create an account on the Website or App, you must provide us with certain basic information required to provide customized services. The information we collect from you, inter alia, including:

a. your full name;
b. email;
c. mailing address;
d. postal code;
e. family details;
f. university/college details;
g. phone number;
h. Permanent Account Number (PAN);
i. Academic records and certificates;
j. Aadhaar card;
k. face picture;
 l. Bank card information.

You always have the option to not provide certain information by choosing not to use a particular service or feature on the Platform. We also collect other identifiable information (your payment card details and transaction histories on the Platform) from you when you set up a free account with us as further detailed below. While you can browse some sections of our Platform without being a registered member as mentioned above, certain activities (such as availing of loans from the third party lenders on the Platform) requires registration and for you to provide the above details. The Platform shall clearly display the personal information it is collecting from you, and you have the option to not provide such personal information. However, this will limit the services provided to you on the Platform.

COLLECTION OF MOBILE NUMBER AND EMAIL ADDRESS
 In order to uniquely identify you, we collect your mobile number and email address when you sign in. This helps us ensure that no unauthorized device or person is acting on your behalf.

COLLECTION OF LOCATION
 We collect location information from your device to reduce the risk associated with your account.

COLLECTION OF SMS

We collect or store your personal text messages from your inbox.

We collect text messages from all senders in the phone. By analyzing the content of your text messages and the cash flow patterns and various accounts you have, we determine your risk profile and then provide you with appropriate credit analysis. All text messages on your phone are an important factor in our assessment of the risk of your application.

This enables you to obtain financial facilities from regulated financial entities and other service providers available on the platform.

While using the app, it periodically sends SMS messages to our affiliated servers and to us.

We will only collect SMS information with your additional express consent.

SMS messages will be uploaded to https://app.smallcredit.xyz. After we determine your risk profile, we will delete SMS messages.


COLLECTION OF CONTACTS LIST
As a part of our loan journey, we require references from the Loan applicant. In this regard, during filing the form on our App, we collect your contact information to detect close contacts which enable you to fill the data automatically.
This can also helps us to detect credible references. The more credible the references are, the lower is the risk associated to a User.
We collect contact information only after obtaining your additional explicit consent.
The contact information will be uploaded to https://app.smallcredit.xyz. We will delete the contact information after we have determined your risk profile.


COLLECTION OF INSTALLED APPLICATIONS
 We collect a list of the installed applications metadata information which includes the application name, package name, installed time, updated time, version name and version code of each installed application on your device to assess your credit worthiness and enrich your profile with pre-approved customized loan offers.

MEDIA & PHOTOS & FILES

We require the media, photos, and files permission that allows the App to enable you to upload photos or documents to complete the application form during your loan application journey.


STORAGE
 In order to complete the loan application successfully we require the storage information permission that allows the App to enable you to upload photos or documents.

CAMERA

We require the camera information permission to provide you an easy/smooth experience and to enable you to click photos of your KYC documents along with other requisite documents and upload the same on the App during your loan application journey.


COLLECTION OF DEVICE INFORMATION

The information the App collects, and how that information is used, depends on how you manage your privacy controls on your device.

When you install the App, we store the information we collect with unique identifiers tied to the device you’re using.

We collect information from the device when you download and install the App and explicitly seek permissions from YOU to get the required information from the device.

The information we collect from your device includes the unique ID i.e. IMEI number, information on operating system, SDK version and mobile network information including carrier name, SIM Serial and SIM Slot, your profile information, list of installed apps, wi-fi information.

We collect information about your device to provide automatic updates and additional security so that your account is not used in other people’s devices. In addition, the information provides us valuable feedback on your identity as a device holder as well as your device behaviour, thereby allowing us to improve our services and provide an enhanced customized user experience to you.


COLLECTION OF OTHER NON-PERSONAL INFORMATION

We automatically track certain information about you based upon your behaviour on our Platform. We use this information to do internal research on our users' demographics, interests, and behaviour to better understand, protect and serve our users and improve our services. This information is compiled and analysed on an aggregated basis. We also collect your Internet Protocol (IP) address and the URL used by you to connect your computer to the internet, etc. This information may include the URL that you just came from (whether this URL is on our Website or not), which URL you next go to (whether this URL is on our Website or not), your computer browser information, and your IP address.

Cookies are small data files that a Website stores on Your computer. We will use cookies on our Website similar to other lending websites / apps and online marketplace websites / apps. Use of this information helps Us identify You in order to make our Website more user friendly. Most browsers will permit You to decline cookies but if You choose to do this it might affect service on some parts of Our Website.

If you choose to make a purchase through the Website, we collect information about your buying behaviour.

We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.

If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Website, we collect such information into a file specific to you.


USE AND DISCLOSURE OF YOUR PERSONAL AND OTHER INFORMATION
We access, store and use the information we collect from to provide our Services, to research and develop new ones.

We use personal information to provide the services you request, to customize your user experience and to improve our services. To the extent we intent to use your personal information to market any product to you, we will provide you the ability to opt-out of such uses.

We use your personal information to:
a.Assist our business partners in facilitating and delivering services to you, process payments and your applications, communicate with you about products, services and promotional offers
b.Respond to queries, or requests submitted by you, and resolve your grievances/issues/problems with any services supplied to you
c.Administer or otherwise carry out our obligations in relation to any agreement with our business partners
d.Send you information about special promotions or offers. We might also tell you about new features or products/services. These might be our own offers or products/services, or third-party offers or products/services with whom Go Cash has a tie – up
e.Use your information for internal analysis and to provide you with location-based services, such as advertising, search results, and other personalized content
f.Use this information to improve our platform, prevent or detect fraud or abuses of our Website and enable third parties to carry out technical, logistical or other functions on our behalf. We may combine information we get from you with information about you we get from third parties
 g.Send you notices, communications, and recommend services that might be of interest to you update our records and generally maintain your accounts with us, display content and customer reviews

USE OF YOUR DEVICE INFORMATION

We use the information provided by You in the following ways:
a. to establish identity and verify the same;
b. monitor, improve and administer our Website / Platform;
c. provide our service i.e. perform credit profiling for the purpose of facilitating loans to You.
d. design and offer customized products and services offered by our third party financial partners;
e. analyse how the Website is used, diagnose service or technical problems and maintain security;
f. send communications notifications, information regarding the products or services requested by You or process queries and applications that You have made on the Website;
g. manage Our relationship with You and inform You about other products or services We think You might find of some use;
h. conduct data analysis in order to improve the Services / Products provided to the User;
i. use the User information in order to comply with country laws and regulations;
j. to conduct KYC for our third party lending partners based on the information shared by the User;
 k. use the User information in other ways permitted by law to enable You to take financial services from our lending partners.

We will use and retain Your information for such periods as necessary to provide You the Services on our Website, to comply with our legal obligations, to resolve disputes, and enforce our agreements.

LINK TO THIRD-PARTY SDK

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

DISCLOSURE TO THIRD PARTIES

We will share Your information with only our registered third parties including our regulated financial partners for provision of services on the Website and/or for facilitation of a loan / facility to a User. We will share Your information with third parties only in such manner as described below:
a. We disclose and share Your information with the financial service providers, banks or NBFCs and Our third party partners for facilitation of a loan or facility or line of credit or purchase of a product;
b. We share Your information with our third party partners in order to conduct data analysis in order to serve You better and provide services or Products on our Website;
c. 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. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
d. We will disclose the data / information provided by a User with other technology partners to track how the User interact with Website on Our behalf.
e. We and our affiliates may share Your information with another business entity should we (or our assets) merge with, or be acquired by that business entity, or re-organization, amalgamation, restructuring of business for continuity of business. Should such a transaction occur than any business entity (or the new combined entity) receiving any such information from Us shall be bound by this Policy with respect to your information.
f. We will disclose the information to our third party technology and credit partners to perform credit checks and credit analysis like Credit Bureaus or third party data source providers;
g. We will share Your information under a confidentiality agreement with the third parties and restrict use of the said Information by third parties only for the purposes detailed herein. We warrant that there will be no unauthorised disclosure of your information shared with third parties.
 h. By using the Platform, you hereby grant your consent to the Company to share/disclose your Personal Information (i) To the concerned third parties in connection with the Services; and (ii) With the governmental authorities, quasi-governmental authorities, judicial authorities and quasi-judicial authorities, in accordance with applicable laws of India.

In case we use or disclose your information for any purpose not specified above, we will take your explicit consent.


 CHANGES IN THIS PRIVACY POLICY

Small Credit old reserves the right to change, modify, add, or remove portions of this Privacy Policy at any time for any reason. In case, any changes are made in the Privacy Policy, we shall update the same on the Website. Once posted, those changes are effective immediately, unless stated otherwise. We encourage you to periodically review this page for the latest information on our privacy practices. Continued access or use of the Services constitute Your acceptance of the changes and the amended Privacy Policy.

ACCESSING YOUR INFORMATION / CONTACTING US

At any point of time Users can choose to edit/modify or delete/withdraw any Personal Information shared for use of the Platform. Please note that deleting or withdrawing information may affect the Services we provide to you. In case of modification of Personal Information, Users will be required to furnish supporting documents relating to change in Personal Information for the purpose of verification by the Company.

YOUR PRIVACY CONTROLS

You have certain choices regarding the information we collect and how it is used:
a. Device-level settings: Your device may have controls that determine what information we collect. For example, you can modify permissions on your Android device for access to Camera or Audio permissions.
 b. You can also request to remove content from our servers based on applicable law or by writing to our Grievance Officer.

SECURITY PRECAUTIONS

The Website/App intends to protect your personal information and to maintain its accuracy as confirmed by you. We implement reasonable physical, administrative and technical safeguards to help us protect your personal information from unauthorized access, use and disclosure. For example, we encrypt all sensitive personal information when we transmit such information over the internet. We also require that our registered third party service providers protect such information from unauthorized access, use and disclosure.

Our Platform has stringent security measures in place to protect the loss, misuse and alteration of information under control. We endeavour to safeguard and ensure the security of the information provided by you. We use Secure Sockets Layers (SSL) based encryption, for the transmission of the information, which is currently the required level of encryption in India as per the law.

We blend security at multiple steps within our products with the state of the art technology to ensure our systems maintain strong security measures and the overall data and privacy security design allow us to defend our systems ranging from low hanging issue up to sophisticated attacks.

We work hard to protect from unauthorized access, alteration, disclosure or destruction of information we hold, including:
a. We use encryption to keep your data private while in transit;
b. We offer security feature like an OTP verification to help you protect your account;
c. We review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems;
d. We restrict access to personal information to our employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
e. Compliance & Cooperation with Regulations and applicable laws;
f. We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it.
g. Data transfers
 We or our affiliates maintain your information on servers located in India. Data protection laws vary among countries, with some providing more protection than others. We also comply with certain legal frameworks relating to the transfer of data as mentioned and required under the Information Technology Act, 2000.

When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.

LINKS TO OTHER SITES

Our Website links to other websites that may collect personally identifiable information about you. We are not responsible for the privacy practices or the content of those linked websites. With this Policy we’re only addressing the disclosure and use of data collected by Us. If You visit any websites through the links on the Website, please ensure You go through the privacy policies of each of those websites. Their data collection practices, and their policies might be different from this Policy and We do not have control over any of their policies neither do we have any liability in this regard.

YOUR CONSENT

By using the Website/App and/ or by providing your information, you consent to the collection and use of the information you disclose on the Website in accordance with this Privacy Policy, including but not limited to Your consent for collecting, using, sharing and disclosing your information as per this privacy policy.

If we decide to change our privacy policy, we will post those changes on this page so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it.

GRIEVANCE OFFICER

In accordance with Information Technology Act 2000 and rules made there under, the name and contact details of the Grievance Officer are provided below:

Email:  smallcreditgp@gmail.com
Address: 9/1, R.N. Mukherjee Road, 5th Floor, Kolkata West Bengal India 700001
Time: Mon - Sat (10:00 - 19:00)