PRIVACY POLICY

ASSURED SUM FINANCIAL SOLUTIONS PRIVATE LIMITED (hereinafter referred to as “We” or “Us” or “Our” or the “Company”) are committed to protecting and respecting the privacy of its users (hereinafter referred to as “You” or “Your”). To protect the Your privacy while sharing Personal Data, this “Privacy Policy” is prepared by the Company in compliance with applicable provisions of the Information Technology Act, 2000, Information Technology Rules, 2011, the Digital Personal Data Protection Act, 2023 and other national and state laws which relate the processing of Personal Data.

 

A. We encourage You to read this “Privacy Policy” to learn more about Our practices, and procedures, concerning the collection of Personal Data, the purpose for which Your Data is being collected, details of third parties with whom Your Personal Data will be transferred/shared, and Your rights.

 

B. We may collect sensitive Personal Data from You or receive it from You to provide services on Our website as well as on Our mobile application purely based on consent provided by you to us. If You provide Us with the requisite information, it is implied that You have provided explicit consent for Us to process Your Data. If You choose not to provide Us with the requisite information of Yours then in that case, We may not be able to provide You the services You desire or You may not be able to access and derive benefit from the portal or mobile application accordingly.

 

C. We neither hold any requisite license, permission or any approval to carry on any activities relating to lending or borrowing nor are registered with the Reserve Bank of India (“RBI”). The Company also states that it is not a Bank or a Financial Institution or a Non-Banking Finance Company under the Companies Act, 2013, the Banking Regulation Act, 1949 or any other laws of India thus the Company is not engaged in any type of lending directly or indirectly in any manner whatsoever and the Company does not have any plans or intention to undertake any form of borrowing or lending. The Company is only a direct selling agent and is authorized by various banks, NBFCs, financial institutions, etc., to act as their representative while reaching out to the prospecting customers.

1. PERSONAL DATA

 

“Personal Data” refers to any information that relates to an identified or identifiable natural person. This includes data that can directly identify an individual (such as a person’s name, identification number, or address) as well as information that, when combined with other data, can lead to the identification of an individual. Examples of a few of the Personal Data that We may collect are as follows:

 

i. Basic Information: We may collect Your basic information such as Your first name, last name, mobile number, email address, residential address, photocopy, and referral code (if any);

ii. Financial Information: We may collect Your financial information such as bank account details, credit card numbers, income tax return or any other financial creditworthy ness documents, etc. to the extent permitted by applicable laws;

iii. Demographic Information: We may collect details regarding Your age, gender, ethnicity, marital status, etc.

iv. Identity: We may collect Your identity documents including but not limited to Aadhar copy, PAN copy or any other documents that may be required by Us and information relating to “KYC” (Know Your Customer) to complete the customer due diligence requirements and to comply with the customer identification procedures and share the same with third parties in accordance with applicable laws.

v. Device Information – We may collect Your device information such as the device’s internal protocol (IP) address, operating system software, browser type, device type, device international mobile equipment identity (IMEI) and the date and time at which You access Our website or application to derive benefits from the services We provide.

vi. Short Messaging/ Message Service (SMS): We may need access to Your SMS functionality to keep You updated with Our latest policies, rules, or any other information that You have to be aware of, to share a one-time password whenever You log in from a new device or whenever You change or forget Your password and also to provide You to access Our portal/ application without any restriction.

vii. Information collection on usage: We may collect information that You submit to Us on Our website in the form of comments, messages, reviews, ratings, feedback, information about searches, and details of Your visit to Our website or mobile application. The

purpose of retaining this information is to optimize the administration task and to analyze statistically the traffic of users on Our portal. Additionally, We may use this information to send You any updates, or information that You have to be aware of via email and/or SMS. Provided that if such additional information is not regarding the loan, due payments or document updates You may prevent such communications if not interested.

viii. Camera Access: For Your hassle-free experience, We may require access to Your camera, to allow You to click a selfie, or to upload any documents or photos for the purpose of You to update profile and “KYC”.

ix. Location Access: We may collect Your location details and monitor Your location whenever required to verify Your addresses, offer customized promotions, and ensure to provide the best services in Your locality or to prevent any fraud from happening/detect fraud if any. We collect Your location data either by requesting Your residential address, and pin code or by requesting to enable Us to track down Your location electronically when You log in to the portal or mobile application. In case, You withdraw or disable access, Our services to You may be restricted.

x. Storage Access: For Your seamless experience on Our portal and mobile application We may need storage access from Your device for the purpose of uploading or downloading documents which may be required.

xi. Third-party applications: We may in Our capacity as a facilitator periodically collect the metadata information of apps installed on Your device for the purpose of sharing such data with the business partners to provide the services.

xii. Any other Information: Apart from collecting data directly from You We may collect data that is available from business partners or is available on social networks, registries, internet sites, or any other related media.

 

2. PURPOSES OF USING PERSONAL DATA

 

We may require Personal Data to provide You with various services such as:

 

i. to provide Our services;

ii. to comply with the applicable laws and to perform the duties/obligations stated under the lawful contract executed with You,

iii. to establish Your identity and verify the same periodically;

iv. to complete the “KYC” as mandated by the RBI or as per the applicable laws;

v. to provide unrestricted access to Our website/portal and mobile application;

vi. assessing eligibility, underwriting, and facilitating loan transactions;

vii. to solve troubleshooting problems, monitor and improve Our services,

viii. to send communications, updates, notice, to redress any of Your grievances, or to answer any of Your queries, or to provide information about any of Our products or services as requested by You through email/SMS/telecalls;

ix. to send marketing and promotional communications through email/SMS/telecalls regarding the offers We provide to You for Our products and services through email/SMS/telecalls;

x. to enhance Your experience and to enforce Our terms and conditions;

xi. to disclose the Personal Data with any third party including but not limited to Employees, Contractors, Officers, Business Partners, Service Providers, Affiliates, Agents, Representatives, Government Authority, Government Department(s), Court(s), Tribunal(s), Regulatory Authority(ies), Bank(s), Financial institution(s), Non-Banking Financial institution(s), Housing Finance Company(ies), etc., on a “need-to-know basis”.

xii. to fulfil any other purpose for which prior consent has been obtained from You.

 

3. SHARING OF PERSONAL DATA

 

We may share Your Data with:

i. the Reserve Bank of India, NPCI, Credit Information Companies, Financial Institutions or any other regulatory agencies to ease the provision of services or to comply with any applicable laws that are in force;

ii. with Holding Company(ies), Subsidiary Company(ies), Affiliated Company(ies) or any other Body Corporate(s) under common control;

iii. Business Partners, Bank(s), Financial institution(s), Non-Banking Financial institution(s), Housing Finance Company(ies), etc., who are ready to provide You with the service;

iv. to internal or external technical or customer support team for sending You emails/SMS containing information regarding the offers or services We provide for You which You

may have shown interest in, push reminder notifications via email/SMS/telecall in case of any dues pending or to acknowledge the payments received from Your end;

v. we may also send Your data to third parties to survey Your financial creditworthiness before processing the loan amount by the banks or any other financial institution or in case of default on the payment and not responding to Our communications to find Your whereabouts;

vi. in future in the event of merger, amalgamation, acquisition, restructuring, reorganising, dissolution, whether or not ongoing bankruptcy, liquidation or any other similar proceedings, or sale/transfer of any or all of the assets to the purchaser/buyer/transferee/successor. We hereby agree that Your Personal Data will be shared/transferred only if Your Personal Data is among the assets transferred and only if it is necessary for the services to be provided to you;

vii. Law enforcement agencies, courts, tribunals, regulatory bodies established under any law, or any other government bodies that have jurisdiction to comply with the laws, orders, rules, regulations or government directives;

viii. to any other individuals/entities/body corporates to enforce the terms and conditions of this privacy policy or any other, and also to perform the obligations/duties mutually decided by executing the lawful contract;

ix. in any other circumstances, wherein the transfer/sharing of information is requisite to which We have obtained Your prior consent.

 

4. THIRD-PARTY POLICIES

 

In general, We may use, collect, retain, process, share or transfer Your Data with third parties to which You are hereby giving Your prior consent and We are not obligated to obtain any other consent. While using, collecting, retaining, processing, transferring, or sharing Your Personal Data, we will use Our utmost precautions to ensure that all the third parties are also complying with the terms and conditions stated under this Privacy Policy and all the applicable laws. In addition to the terms and conditions stated under this Privacy Policy, We will use Our utmost precautions to ensure that the third parties maintain confidentiality and abide by the confidentiality obligations.

 

Despite the terms and conditions stated under this Privacy Policy, We encourage You to go through the Privacy Policies of Our Business Partners/ Service Providers that have their respective privacy policies. We bring to Your attention that a few third-party Business Partners/ Service Providers with whom We are affiliated may be located or have facilities in different jurisdictions. In that case, if You opt for such third-party services then Your Personal Data may become subject to the laws governing that jurisdiction.

 

In case You press any link available on Our website or mobile application that redirects to any third-party portals/websites and if You provide any of Your Personal Data to such third parties, please be aware in such scenarios terms and conditions stated in this Privacy Policy will no longer be applicable. We will not be liable for any acts or omissions of the third-party Business Partners/ Service Providers and You hereby agree that You shall be personally liable and responsible while sharing Your Data with third parties.

 

5. OUR SECURITY PRACTICES AND POLICIES

 

We give utmost importance to protecting Your valuable Personal Data as if the data belongs to Us. Further, as mandated by the applicable laws We implement reasonable security practices and procedures. These security practices and procedures include managerial technical and operational safeguards, physical security control measures, restrictions on unauthorized access and disclosure and use of Personal Data to prevent any fraud.

 

We use servers that have firewalls and SSL (secure sockets layer) certificate installed while transferring/sharing Your Personal Data to any third party or when receiving such Personal Data from Your end. Further, we actively adhere to practices like encryption and data anonymization.

 

6. CONSENT WITHDRAWAL AND RECTIFICATION

 

You can access and review the Personal Data, or any other information provided to Us by getting in touch with Our team @support@assuredsum.com You also have a right to withdraw or revoke Your consent at any point of time by writing an e-mail to Our team @ support@assuredsum.com . Once the purpose for processing Your information is fulfilled, We

will make sure not to retain any of the Personal Data provided to Us, unless mandated by applicable laws or to achieve the purpose of this Privacy Policy.

 

We urge You to provide Us with true information to Your knowledge. In the event of any inaccurate, incorrect, incomplete, misleading, or outdated information We request You to provide the accurate, correct, complete, updated information at the earliest possible but in no case later than Two (2) days from the date of Your becoming aware.

 

7. RIGHT TO MODIFICATION

 

We reserve the right to alter, modify, change, insert, and amend this Privacy Policy from time to time as deemed fit to Us for that We are not obliged to send any prior notice to You. However, We encourage You to go through this Privacy Policy periodically. Note that after the alteration, amendments, insertion, and modification if You avail of any of the services provided by Us either on the mobile application or website it is implied that Your consent/acceptance is obtained by Us for the updated Privacy Policy.

 

8. COOKIES

 

When You visit Our website/portal or mobile application, We may send cookies to Your device:

 

i. to enhance a seamless experience in browsing the website/portal or interacting with Our mobile application;

ii. to store Your search preferences and to improve the search results if and when necessary;

iii. to remember if You are already registered and whether to show certain notifications that might only be valid for subscribed/ unsubscribed users;

iv. to track things like how much time You spend on Our site and the pages that You visit so that We can continue to create interesting content. You may visit the official Google Analytics page for more information on cookies.

 

However, You are provided with the option to disable the cookies at any time. In case You disable the cookies, You may be restricted to certain services and benefits provided by Us either on the website/portal or mobile application.

 

To avoid any ambiguity that may arise in future or for the sake of Your clarity the term “Cookies” indicates small files that will be stored either in Your device storage or hard drive, which helps Us in assisting to provide You with better experience and services.

 

9. SOCIAL NETWORK PLUGINS

 

The website/portal or mobile application incorporates plugins and/ or buttons for social networks, to allow easy sharing on Your social networks. These plugins are programmed so as not to set any cookies when assessing the website/portal or mobile application to safeguard the Personal Data shared with Us. Cookies may be set if You voluntarily make use of the plugin. The collection and use of Personal Data obtained by means of plugins are governed by respective Privacy Policies of social networks.

 

10. INCAPACTY OF A PERSON

 

If You are incapacitated to contract as per the applicable provisions in the jurisdiction in which You reside, You may use Our website/portal or mobile application with the consent of Your Legal Guardian. In any case, We shall not be liable for any cause of action that arose due to non-compliance with this clause.

 

11. INDEMNITY

You agree and undertake to indemnify, defend and hold Us and our employees, officers, and Directors against any loss, claim, liabilities, expenses or in case of any suit or dispute or legal proceeding by any third party arising out of disclosure of Personal Data by You to a third party either through Our Website or otherwise, and Your use and access of websites, applications, and resources of third party. We assume no liability for any actions of a third party about Your Data which You may have disclosed to such third party.

 

12. GOVERNING LAW

This Privacy Policy shall be governed in accordance with the Laws of India and the courts/ tribunals situated in Hyderabad, Telangana, India, shall have exclusive jurisdiction in this regard.

 

13. DETAILS OF GRIEVANCE OFFICER

In the event of any grievances or queries or questions, You may contact Our grievance officer either through email or the phone number provided hereinbelow. Our Grievance Officer will attempt to redress Your grievances or answer Your queries and questions at the earliest possible.

 

Name: Nanda

Destination: Operation Head

Phone Number: 8019 51 4585

E-mail ID: support@assuredsum.com

Address :3rd Floor, Plot 208, Kavuri Hills Road, Madhapur, Hyderabad, 500081