PRIVACY POLICY
KARWT Internet Private Limited (“Company”, “we”, “us” and “our”) recognizes the importance of privacy as well as maintaining confidentiality of the Personal Information shared by its users (hereinafter referred to as “User” or “you” or “your”) while they access, use or avail any services from its technology platform including website or mobile application thereof (“Platform”). This Privacy Policy describes the type of information that Company may collect from you when you access or use our Platform and the practices for collecting, using, maintaining, protecting, and disclosing such information.
By accessing or using the Platform or its services and/or registering for an account with Platform, you agree to this privacy policy and you are expressly consenting to Company's collection, use, disclosure, retention, and protection of your Personal Information as described here. If you do not provide the information we may require, we may not be able to provide all our services to you.
This Privacy Policy (“policy”) applies to the information Company collects through the Platform, or while rendering services thereto, in e-mail, text and other electronic communications sent through or in connection with its services.
This Policy complies with inter alia the provisions of Rule 3 of the Information Technology (Intermediaries Guidelines) Rules, 2011 and other applicable laws that require publishing of privacy policies for collection, usage, storage, disclosure and transfer of information.
All capitalized terms not defined in this document shall have the meanings ascribed to them in the Terms of Use of the Platform, which can be found here.
I.COLLECTION OF INFORMATION
We may collect the following types of information from and about you, including but not limited to:
a.
any information, documents, or details that relate to you, which indirectly or directly or in combination with other information available with us, can lead to your identification which includes without limitation, your name, address, postal code, recent photograph, financial information, accounting information, phone number, fax number, email address (“Personal Information”);
b.
information about your internet connection, the equipment/ device you use to access the Platform and your usage details;
c.
In connection with any communication or transaction and payment services or any other services that you may avail using the Platform, information, including without limitation, bank account numbers, chequebook information, virtual payment addresses, billing and delivery information, credit/debit card numbers/expiration dates/CVV and tracking information from cheques or money orders may be collected, among other things, to facilitate transactions made for the products or services that have been procured by you through this Platform;
d.
Information that gets synced automatically such as, information relating to User’s sales, purchases, inventory, business contacts (supplier list & customer list), payment patterns, bank, Goods and Services Tax (“GST”) information and other commercial information;
e.
Goods and Services Tax (“GST”) registration details for accessing your GST portal on your behalf for provision of services;
f.
synced information while availing Platform Services such as information relating to User’s sales, purchase, inventory, business contacts (supplier and customer list);
g.
information relating to communications or transactions, the types and specifications of the products, pricing, billing and delivery information;
h.
your search history, browsing or buying activities on Platform including but not limited to Internet Protocol (“IP”) addresses, browsing patterns and user behavioural patterns;
i.
GST registration details for obtaining your GST details for provision of services;
j.
communications between you and us or with third party service providers that are providing services via the Platform;
k.
any content, feedback, reviews etc. you may have uploaded or provided to the Company or on the Platform;
l.
statistical information and details of the visitors to the Platform including, but not limited to, IP addresses, browser software, operating system, software and hardware attributes, pages viewed and number of sessions.
m.
after obtaining the User’s specific consent to allow the Platform to access the User’s text messages (SMS) inbox, we may collect relevant transactional/service information from SMS received by the Users from providers of services and/or products (including but not limited to retail outlets, financial institutions, mobile carriers and utility companies), that will enable us to provide better access to financial services and products to the Users. We will only access business messages that originate from alphanumeric senders.
n.
in order to enhance our ability to provide valuable services and experiences to the User, We may: (i) automatically receive, collect and analyse your location information which may be accessed through a variety of methods including, inter alia, IP address, and location; and (ii) collect information pertaining to your device and your usage thereof, including, inter alia, the names of the other applications on your mobile device and how you use them, information about your device, and information about your use of features or functions on your device.
o.
you may choose to provide us with access to certain Personal Information stored by third parties like social networking sites or e-commerce websites (e.g. Facebook and Twitter). We will have access to such information to the extent allowed by the User’s privacy settings on that site and the User’s specific authorization. In the event the User associates a User account managed by us with an account maintained with any third party to enable us to access certain information maintained in such third party managed accounts, the User agrees that we may collect, store and use such information in accordance with this policy.
In the event, you do not provide sufficient personal information about you, we might not be able to complete the registration process or enable your access or use to the Platform or its services or provide you with information about our products and services to the fullest.
We may collect this information directly from you when you provide it to us or automatically as you navigate through the Platform (information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons and other tracking technologies).
II.USE OF PERSONAL INFORMATION
If you provide Personal Information to us, you are deemed to have authorized and expressly consent us to collect, retain and use your information for the below-mentioned purposes:
a.
To verify the identity of the user onboarded on the Platform;
b.
Determine your eligibility for taking loans using, inter alia, using our proprietary technology and such additional rules that may be determined by: Company and/or our lending partners;
c.
Safeguard against illegal activities like fraud, cheating, misappropriation, etc.
d.
To collect, receive, obtain and/or fetch on your behalf, a copy of your credit information report from credit information companies (“CICs”) through us and identity verification services to facilitate banks and other financial institutions to evaluate the user’s loan request in the context of the User’s complete financial situation;
e.
To process user’s registration by providing the user with a log-in ID for accessing the Platform;
f.
To enable the provision of services to you or activities and transactions that need to occur during the process of lending, including without limitation, generating and maintaining User profiles, providing personalized features, facilitating collection services, maintaining regular communications with the User concerning transactions the User initiates, such as requesting information or assistance, submitting a loan request, making payments, transferring funds, etc.
g.
Communicate to you necessary account and product and/or service-related information from time to time;
h.
To allow you to receive customer care services and responding to your queries, claims, disputes or any other concerns;
i.
Administer our services and diagnose technical problems;
j.
Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
k.
To comply with applicable laws, rules and regulations;
l.
To provide you with information with respect to offers on products and services, updates, promotions related to our services or associated with the service providers and partners, that we believe would be of interest to you;
m.
Performing research or statistical analysis in order to improve the content and layout of the Platform, to improve our product offerings and services;
n.
For assessment, evaluation (including credit and/ or behaviour scoring), statistical, market and product analysis and/or market research and to monitor, improve and administer the Platform and its services;
o.
To profile your business and to understand your needs better, and thereby offer you products & services;
p.
To create aggregated products, such as, credit profile, marketing profiles or any other aggregate profile based on the information shared by you;
q.
In any other way we may describe when you provide the information to us; and
r.
For any other purpose with your consent.
You acknowledge that you are licensing us to use, modify, display, distribute and create new material from the information you provide through the Platform to render certain services to you. By providing such information, you automatically agree, or promise that the owner of such information has expressly agreed to allow or license, as the case may be, us to use the information in the manner set out in this policy, without the payment of any fees or royalty. We may, to the extent permitted by law, also use, license, reproduce, distribute disclose, and aggregate, non-personally identifiable information that is derived through your use of the Platform and you hereby provide consent for the same.
III.DISCLOSURE OF PERSONAL INFORMATION
We may disclose personal information that we collect, or you provide, as described in this privacy policy, in the following ways:
a.
To our subsidiaries, group companies and/ or affiliates under the common ownership or control of our parent company.
b.
To third party service provider(s) whom we may use for our business operational purposes or for the performance of any lawful contractual obligation entered into with such provider(s).
c.
In connection with the services being rendered through the Platform.
d.
To third-party service providers who perform services on our behalf which may include without limitation data entry, database management, promotions or marketing activities, products and services alerts, authentication and verification services etc. These third-party service providers shall be under an obligation of confidentiality and will be permitted to use your personal information only in connection with the purposes specified in clause 2 mentioned herein above.
e.
To our professional advisers, law enforcement agencies, insurers, government and regulatory and other organizations or in compliance with court orders, requests/order, notices from legal authorities or law enforcement agencies compel us to make such disclosure.
f.
To third-parties to market their products or services to you if you have consented to receive the promotional updates. We contractually require these third-parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.
g.
To help investigate, prevent or take action regarding unlawful and illegal activities, suspected fraud, potential threat to the safety or security of any person or other user, violations of the Platform’s terms of use or to defend against legal claims.
h.
We may share your Personal Data with third parties including without limitation, banks, financial institutions, credit agencies, or vendors to enable such third parties to offer their products or services. While we shall endeavour to have in place internal procedures to keep User’s Personal Data secure from intruders, there is no guarantee that such measures/procedures can eliminate all of the risks of theft, loss or misuse.
i.
We may share your information when we believe, such disclosure is mandated by applicable law. This may include exchanging or sharing information with other companies, organisations, banks, government or regulatory authorities. However, this does not include selling, renting, or otherwise disclosing personal information for commercial purposes in a way that is contrary to applicable laws.
j.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
k.
We may share your information with any third party in any other circumstances where we have your consent.
IV.THIRD PARTY WEBSITES / OFFERS
(i) We may establish relationships with other parties and websites to offer you the benefit of products and services which we do not offer. We may offer you access to these other parties and/or their websites.
(ii) This policy does not apply to the products and services enabled or facilitated by such third parties. The privacy policies of those other parties may differ, and we have no control over the information that you may submit to those third parties. You should read and understand the relevant privacy policy for those third parties before responding to and availing any offers, products or services advertised or provided by those third parties.
V.RETENTION POLICY
We will retain your information for as long as it is necessary to fulfil the purposes set forth herein, and for a reasonable time thereafter for the furtherance and completion of any of our services to you, and for such time as may be necessary in order to comply with any legal obligation or compliance under applicable laws.
We may be required to retain your information post termination of our business relationship with you for fraud prevention purposes and use such information for the exercise/defense of a legal claim or for providing evidence in legal proceedings or as may be required to comply with applicable laws.
Post termination of your User Account with Indusage, Indusage is not responsible for retaining any of your information or any backups of such information, User shall have no right to request Indusage for any of their information in any form post termination of their User account for any reason whatsoever.
Post termination of your User Account, Indusage may continue to use your anonymized data aggregated or in combination with anonymized data of other users. We use this aggregated anonymized data for data analysis, profiling and research purposes, for example to gain insights about our users and their profiles. We may keep your contact information along with your application details (if any) for fraud prevention purposes and for the exercise/defense of a legal claim or for providing evidence in legal proceeding(s).
VI.PROTECTING OF YOUR PERSONAL DATA
We have employed appropriate electronic, and managerial procedures to safeguard and help prevent unauthorized access to your Personal information and to maintain data security. These safeguards take into account the sensitivity of the information that we collect, process and store and the current state of technology. We follow generally accepted industry standards to protect the Personal information submitted to us, both during transmission and once we receive it. Although we will endeavour to safeguard the confidentiality of your personally identifiable information, transmissions made by means of the internet cannot be made absolutely secure. By using this Platform, you agree that the Platform will have no liability for disclosure of your information due to errors in transmission or unauthorized acts of third parties.
VII.UPDATING THE INFORMATION
To correct or update any information you have provided, the Platform allows you to do it online or by contact the Grievance Officer. In the event of loss of access details, you can send an e-mail to the Grievance Officer.
You will not be able to update the information you have provided in an application on our Platform after a decision has already been made on it; however, you may create and submit a new application with your updated information.
VIII.COOKIES
We may use data collection devices such as “cookies” on certain pages to help analyse our web page flow, measure promotional effectiveness, and promote trust and safety. “Cookies” are small files or small amount of data that is sent to your browser and stored on your device. If you do not de-activate or erase the cookie, each time you use the same device to access the Platform, our services will be notified of your visit to the Platform and in turn we may have knowledge of your visit and the pattern of your usage. Generally, We use cookies to identify User and enable us to
1.
access your Registration Information or Account Information so you do not have to re-enter it;
2.
gather statistical information about usage by you;
3.
research visiting patterns and help target advertisements based on your interests;
4.
assist our partners to track your visits to the Platform and process orders; and
5.
track progress and participation on the Platform. You can determine if and how a cookie will be accepted by configuring the browser which is installed in your device. If you choose, you can change those configurations. If you reject all cookies by choosing the cookie-disabling function, you may be required to re-enter information on the Platform more often and certain features of the Platform may be unavailable.
IX.MINORS
The Platform and its contents are not intended for User(s) who are minors (those under 18 years of age). However, since we have no way of distinguishing the age of individuals who access our Platform. If we become aware that a person submitting Personal Information is under the permissible age, we will delete the account and any related information as soon as possible. If you believe we might have any information from or about a user under the permissible age, please contact us the Grievance Officer.
X.TESTIMONIALS
With your express consent, we may post your testimonial about our services with your name and other details.
XI.CHANGES TO THIS PRIVACY POLICY
This policy may change from time to time and your continued use of the Platform and its services thereof after it makes any change is deemed to be acceptance of those changes, so please check the policy periodically for any updates. Once posted on the Platform, the new Privacy Policy will be effective immediately. You agree that any information we hold about User will be governed by the latest version of the Privacy Policy, as amended and reinstated from time to time.
XII.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:
Kuldeep Singh
Grievance Officer, Karwt.com
Village Lukadari, Tehsil Rampurmaniharan
Saharanpur Uttar Pradesh - 247453.
Time: Mon - Fri (11:00 AM - 05:00 PM)