PRIVACY POLICY
Last Modified on : 22nd Feb 2024
Juspay is dedicated to informing You on how we will collect, store, protect, use, and share Your personal information when You use our Services.
GENERAL
This Privacy Policy describes Juspay Technologies Pvt. Ltd. (hereinafter referred to as “Juspay” “We”, “Us”, or “Our”), practices and the privacy rights of users of Services (“You”) regarding our collection, use, storage, sharing and protection of your Information. You agree that Your use of Juspay's Loan Marketplace Services implies Your consent to the collection and use of Your Information in accordance with the terms of this Privacy Policy ("Privacy Policy").
Juspay, through its website/platform and/or any other interface managed or provided by Juspay or its partner merchants, offers a loan marketplace, wherein through the lending partners onboarded by Juspay, the end-customers can avail loan/credit facility for purchasing products or services from an e-commerce merchant (collectively referred to as “Services”) We may amend this Privacy Policy at any time by posting a revised version on our website. The revised version will be effective as of the published effective date, indicated at the top of this Privacy Policy, in which case You will be deemed to have accepted the updated Privacy Policy if You continue to use the Services after the new Privacy Policy takes effect.
1. WHAT IS PERSONAL INFORMATION AND WHAT TYPES OF PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?
“Personal information” means any personally identifiable information that relates to an individual, as defined under Information Technology Act, 2000 or any rules made thereunder (as amended from time to time) or relevant data protection law in India .
“Sensitive Personal Information” shall mean any information categorised as ‘sensitive information’ under IT (Reasonable Security Practices and procedure and Sensitive Personal data or Information) Rules, 2011 or any other act or rules enacted under IT Act, 2000.
Below is a table of the categories of Personal Information and Sensitive Personal Information which we may collect about You:
| Categories of Sensitive Personal Information | Which includes information such as: | Purpose |
|---|---|---|
| "Identification and other related Information" | Full name(s), title, age, gender, and Your date of birth, Your PAN number, Mother’s name, Father‘s name. | To process your loan application Managing our relationship with you or your business. Communicating with you about our and our business partners’ products and services. Delivering the Juspay’s loan marketplace Services to you To process Your information for the purpose of ensuring compliance under applicable laws and for resolving or contesting any claims made by or against You against Juspay, partner credit information companies, financial partners or any other third party. Operating our business in an efficient and proper way, including managing our financial position, business capability, planning, and audit. |
| "Contact Information" | Mobile number(s), permanent and current address, state/city of residence, country, pin code, email address. | |
| "Camera Access" | Mobile device camera for clicking Your selfie and to upload photos of Your KYC documents and any other necessary documents for facilitating the loan process. | To facilitate our lending partners to conduct your Know Your Customer (KYC) check. To authenticate and validate Your access to the services or to mitigate and protect against identity theft or fraud. |
| "Location" | Your location to verify Your current address, ensure serviceability and to prevent any fraudulent activity. | |
| "Financial Information" | Personal bank account numbers and bank account data including e-nach, NEFT, IMPS and UPI ID details, credit or debit card information, including the credit or debit card number, card type, expiry date on the credit or debit card, and name on the card, salary and income details. | To process your transaction for payment of down payment, if any. |
| "Payment Information (transactional information)" | Payment gateway ID, name of issuing bank, merchant’s name, category and other identifiers along with the details of products or services purchased or paid for, mode of payment, the date, currency and amount of the transaction, whether the payment was successful, and other information provided by You directly or indirectly to us or provided to us by banks, merchants or other service providers or business partners. | |
| "Usage and Technical Information" | Web page related data that includes url, title, page load time and size of the page; Any error messages generated during display of the page or during a user interaction; User action data that includes canceling the transaction, clicking any elements on the page. IP addresses, application, device or browser type, versions and configurations, operating systems, device brand and model, time zone setting, geo-location information, content, unique identifiers associated with Your device(s) and pages that You access on the interface, website, Apps or other platforms, and the dates and times that You visit the website,app or platform, and paths taken. | Delivering our products and services to you. Delivering our and our business partners’products and services. Identifying, investigating, reporting and preventing fraud, money laundering and other crime. Developing and carrying out marketing or business development activities. |
| “Credit and Lending Information” | To the extent permitted under applicable laws of India. It includes Credit or affluence related information or assessment, Credit Information and income information (e.g., employment contract, salary details, employer name, bank income statements,), credit or affluence score or reliability scores provided by third parties such as financial institutions or account aggregators or similar third parties as permitted under applicable laws of India. It includes any information relating to: (i) the amounts and the nature of loans or advances, amounts outstanding under credit cards and other credit facilities granted or to be granted, by a credit institution to you; (ii) the nature of security taken or proposed to be taken by a credit institution from you for credit facilities granted or proposed to be granted to you; (iii) the guarantee furnished or any other non- fund based facility granted or proposed to be granted by a credit institution to you; (iv) your creditworthiness; (v) any other matter which may be prescribed as being necessary for inclusion in the credit information to be collected and maintained by Juspay. | To determine your creditworthiness and find the best matched lender(s). |
| “Marketing and Communications Information” | Any emails, calls or other communications you’ve sent to us or we’ve sent to you What we learn about you from communications between us | Communications with customer through support services. Investigating and responding to your enquiries, complaints and feedback |
2. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
How we collect Personal Information (including Sensitive Personal Information) will depend on the following broader situations:
2.1. If we receive or collect it directly from You, when you use our platform i.e. avail loan marketplace Services from our partner merchant’s website/application.
For example, The details You voluntarily enter during the course of using the Services.
2.2. We collect your Information when you voluntarily provide such information on our platform and/or to our partner merchant’s agent for availing loan marketplace Services.
We collect Personal Information (including Sensitive Personal Information) directly from You in different ways on the website, merchant platforms or through merchant’s agents.
For example, You give us Your Personal Information (including Sensitive Personal Information) when You:
- give us Your Contact Information, to avail our services and products;
- give any Personal or Sensitive Personal Information to our partner merchant’s agent (whether by email, phone or electronic messaging) for availing loan/credit facility through loan marketplace Services. ;
- provide Your Personal Information (including Sensitive Personal Information) for availing product or services offered by Juspay on these websites, merchant platforms or the checkout pages in order for availing our services or for completing a transaction(s);
- give us Your Credit and Lending Information to avail any loans, EMI options or any other services directly from us, or from our business partners;
- send us a support request for any of our products or services through one or more of our support desks; or
- access, use and/or browse our product through merchant platforms or this website;
- give us permission to collect the same from Your device and other sources available through various means including cookies.
Juspay is authorized by its Financial partners to collect your Financial Information to assess the creditworthiness checks for providing You the services.
2.3. If we collect it from third parties, or from publicly available sources
We obtain Personal Information (including Sensitive Personal Information) through third parties including our partner merchants, credit information companies, financial partners, as permitted under applicable laws of India, including:
- from various merchants. For example, a merchant can share Your information with us e.g. Length of customer’s relationship with such merchants, Number of past purchases made by You on merchants’ platform, etc. for the purpose of doing an eligibility check for our services.
- from credit information companies for checking your credit worthiness. For example, before we provide or enable the provision of any services to You (as applicable), we may undertake credit worthiness checks for providing You the services. These checks require us to collect information about You from our partner credit information companies who have entered into contracts with us
- from our lending partners when you avail loan/credit facility from such lending partners. For example, we receive the details of the EMI scheme (No. of installments, tenure, loan amount etc.) availed by you from a lending partner through loan marketplace Services.
- We encourage you to read such third parties’ privacy statements to learn more on how they process your personal information. d) from third party service providers including service providers engaged in the business of collecting data from publicly available sources, who have entered into contracts with us to assist us with our business operations;
3. LAWFUL GROUNDS FOR PROCESSING SENSITIVE PERSONAL INFORMATION
We process Sensitive Personal Information only when we have obtained Your consent in the manner provided hereunder.
For collecting, processing (including using and storing), disclosing or sharing Your Sensitive Personal Information as described in this Privacy Policy, we hereby through this Privacy Policy, seek Your consent and give You a notice regarding collecting, processing (including using and storing), and sharing Your Sensitive Personal Information for one or more of the purposes detailed herein. For any purposes, where, as per applicable laws of India, a specific or explicit consent is required, we will seek such specific or explicit consent from You from time to time.
4. INFORMATION COLLECTED FROM AND SHARED WITH THIRD PARTIES
We collect Personal Information from and share to a number of different third-parties, including our Financial Partners, Merchants, CIC, etc.
| Type of third party | Description | Collect | Share |
|---|---|---|---|
| Financial Partners | We share your personal and/or Sensitive Information details such as your name, Permanent Account Number (PAN), mobile no., age, gender, economic profile, information related to your creditworthiness etc. with our lending partners for them to be able to provide you loan offers | ✓ | ✓ |
| CICs | We share details such as Name, Contact details, PAN Card, OTP with CIC for obtaining your credit report. | x | ✓ |
| Merchants | We share details related to the loan availed by you with Merchants. | ✓ | ✓ |
| Support tools and operational partners | These include analytics, search engine service providers, customer experience support platform to optimize and improve our services, as well as sub-contractors we may use to supplement our customer support services | ✓ | ✓ |
| Hosting and IT service providers | IT vendors, including cloud storage providers, to securely store your personal sensitive Information | x | ✓ |
| Payment processing partners and vendors | Financial service providers, including payment processors and banking partners to facilitate payment transactions. | x | ✓ |
| Identity and other information verification providers | We work with third parties to verify the information you provide to us, for example your identity and address | x | ✓ |
| Government and regulatory organisations | Government, law enforcement agencies, authorities and regulatory bodies when Juspay has to comply with its legal obligations. | x | ✓ |
5. DATA RETENTION
Juspay may store Your Personal Information and Sensitive Personal Information for as long as the same is required for the fulfilment of purposes for which we collected it. The retention of Personal Information and Sensitive Personal Information by Juspay is determined by considering compliance with legal (contractual, statutory or regulatory requirements), accounting and compliance reporting requirements. Regulatory requirements dictate that we should retain your personal information for five years or other such period notified by the regulator, following the closure of your loan account. Unless you instruct us otherwise and subject to applicable laws, we retain the information we collect for as long as needed to provide our services and to comply with our legal obligations, resolve disputes and enforce our agreements if applicable.
6. YOUR RIGHTS
We ensure that You may exercise Your individual privacy rights under applicable privacy and data protection laws and as per our internal policies. This means that Juspay seeks to provide reasonable assistance to cater to requests from individuals regarding the processing of their Personal Information, in accordance with applicable laws. You can exercise the following rights:
Review, Correct or Rectify Your Personal Information: You can ask us to have inaccurate Personal Information (including Sensitive Personal Information) we process about You, reviewed, fixed or changed in the time frame as specified in the applicable law.
Right to withdraw Your consent: You may withdraw Your consent to processing that You have given Us and prevent further processing of Your Sensitive Personal Information. You should inform Juspay directly that You don’t want Us to process Your Sensitive Personal Information. You are required to make such a request in writing at the below mentioned email address. Please note if you do withdraw your consent, we will not be able to provide you with the services and or other functions or offerings for which this Personal Information was collected. You may, of course, decline to share certain information with us, in which case this may affect our ability to process Your Personal Information (including Sensitive Personal Information) and may therefore lead to the non- availability or discontinuation of the Services for which such Personal Information (including Sensitive Personal Information) are to be used or was being used.
You may also request deletion of your personal data in accordance with the Privacy Policy, provided however, Juspay Technologies as LSP and the Lenders may still retain the loan related data as required under applicable law and to the extent that any amounts are outstanding under any Credit Products or till the time credit limit is available to You.
Right to be forgotten: Where you believe that any Personal Information (including Sensitive Personal Information) collected by us has served the purpose for which it was collected or if such Personal Information is no longer necessary for such purpose the purpose, you may make a request to restrict the disclosure or processing of such Personal Information.
Right to restrict disclosure to third parties: You may withdraw your consent or opt out at any time to disclose your Personal Data (including Sensitive Personal Information) to third parties related to the services. However if you restrict Juspay from disclosing Personal Data (including Sensitive Personal Information) to third parties, we will not be able to provide you with the services and or other functions or offerings for which this Personal Information was collected.
Please submit a request at grievance.credit@juspay.in , if You would like to exercise any of the above rights. These rights are limited in some situations, such as where we are legally or otherwise bound to process or retain Your Personal Information (including Sensitive Personal Information). Please note that this may also affect our ability to provide you and/or our process or enable Your Personal Information (including Sensitive Personal Information) and may therefore lead to the discontinuation of those services or products for which this Personal Information (including Sensitive Personal Information) was being used for, at our sole discretion. Please note that You do not have an unqualified right under applicable laws for deletion of Your Personal Information (including Sensitive Personal Information).
7. SECURITY AND CONFIDENTIALITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, changed, shared or accessed in a way it shouldn’t be. We will employ adequate technical and organisational security measures to protect your personal data. These methods include:
- The pseudonymisation and encryption of personal data, where possible.
- Ensuring the ongoing confidentiality, integrity, availability and resilience of processing systems and services via role-based access controls, confidentiality undertakings of our staff, etc.
- The ability to restore the availability and access to personal data quickly in the event of or technical incident.
- A process for regularly testing, assessing and evaluating the effectiveness of our technical and organisational measures.
We will also limit access to your personal data to employees, agents, contractors and other third parties who have a strict need to see it in order to perform their business functions. They will only process your personal data on a ‘need-to-know’ basis, pursuant to our instructions and they will keep your personal data confidential.
We have put in place procedures to deal with any suspected personal data breach and will let you and any applicable regulator know of a breach when we have to by law.
8. MINORS
Juspay and/or any available products or services provided by Juspay are not directed at or intended for minors, according to minimum age equivalent under applicable Indian laws. However, Juspay recognizes that children under the age of 13 may potentially access the website and/or the Services, products, or merchant platform.
Please also note that Juspay, this website or any product or services provided by Juspay are not directed at or intended for minors. If we learn that we collected the Personal Information (including any Sensitive Personal Information) of a minor, without first receiving a verifiable parental consent, we will take reasonable steps to delete the information in a manner consistent with applicable laws of India as soon as possible.
9. CONTACT US WITH ANY QUESTIONS OR CONCERNS (GRIEVANCE REDRESSAL)
If You have any grievance or complaint, questions, comments, concerns or feedback in relation to the processing of information or regarding this Privacy Policy or any other privacy or security concern, you can write to us at the below email address. You may address any complaints or discrepancies in relation to the processing of Your Personal Information to the grievance officer, mentioned herein below.
Please also note that Juspay, this website or any product or services provided by Juspay are not directed at or intended for minors. If we learn that we collected the Personal Information (including any Sensitive Personal Information) of a minor, without first receiving a verifiable parental consent, we will take reasonable steps to delete the information in a manner consistent with applicable laws of India as soon as possible.
Mr. Ankan Sengupta
Grievance Officer
Juspay Technologies Private Limited
Email: grievance.credit@juspay.in
You also have the right to complain to the regulator. The Reserve Bank of India is the regulator of all Banks and NBFC and system participants engaged by Banks and NBFCs. You can lodge a complaint over the (Complaint Management System) portal of RBI or the Sachet Portal, through the links provided below.
Please note that before approaching the RBI Ombudsman, it is mandatory to first file the complaint with the concerned Regulated Entity (RE) i.e. respective Bank or NBFC from whom you have availed services. Only in the event of non-receipt of reply, within 30 days from the lodging of any complaint, from the RE or if the complaint is rejected wholly or partially by the RE, the complaint can be registered with the Ombudsman
https://sachet.rbi.org.in/home/index
https://cms.rbi.org.in/cms/indexpage.html#
