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Digital Lending Privacy Policy


LAST UPDATED: [21st November 2022]

Psi Phi Global Solutions Private Limited (“Company”, “We”, “Us”, or “Our”), a private limited company with its registered office at 5th Floor, Incubex HQ, 339, 14th B Cross Rd, Sector 6, HSR Layout, Bengaluru, Karnataka 560102, India which owns and operates the website https://okcredit.com/ and/or the mobile application ‘OkCredit’ (collectively referred to as the “Platform”) is committed to protecting Your privacy and the information that You share while using the Platform. We value the trust You place in Us. That’s why, We maintain the highest security standards for securing the transactions and Your information.

The Company facilitates digital lending for the users of the Platform (“Services”), where such financial products are extended by the lending partners i.e. non-banking financial companies. This privacy policy (“Privacy Policy”) applies only to the users accessing the Platform to avail the Services in relation to facilitation of digital lending/financial products. In the event You are accessing the Platform for any other services provided by the Company, as specified in the Terms (defined below), please see Our privacy policy available at Privacy Policy.

This privacy policy (“Privacy Policy”) specifies the manner in which personal data and other information is collected, received, stored, processed, disclosed, transferred, dealt with or otherwise handled by the Company, in relation to the Services. This Privacy Policy does not apply to information that You provide to, or that is collected by, any third-party through the Platform, and any Third-Party Sites (defined below) that You access or use in connection with the Services offered on the Platform.

Please read the Privacy Policy carefully prior to using or registering on the Platform or accessing any material, information or availing the Services through the Platform.

By visiting the Platform or setting up/creating an Account on the Platform for availing the Services and clicking on the “I accept” button provided on the Platform, You (“You”, “Your” as applicable) accept and agree to be bound by the terms and conditions of this Privacy Policy. This Privacy Policy is incorporated into and subject to Our terms of use (“Terms”) and shall be read harmoniously and in conjunction with the Terms. All capitalized terms used and not defined in this Privacy Policy shall have the meaning ascribed to them under the Terms.

This Privacy Policy (i) is an electronic record under the Information Technology Act, 2000 read with rules and regulations made thereunder and is generated by a computer system; and (ii) will not require any physical, electronic, or digital signature.

  1. Collection of Information:

We collect Personal Information (defined below) from You when You register or set up an Account with Us or avail a financial product on the Platform, or at such other instances as may be required for availing the services on the Platform. You may browse certain sections of the Platform without being registered with Us. However, to avail certain Services on the Platform You are required to set up an Account with Us.

This Privacy Policy applies to the following information:

  1. Information You give Us:  You may provide certain information to Us voluntarily while registering on Our Platform and creating an Account for availing Our Services or at such other instances as may be required for availing the Services, such as name, mobile number, Permanent Account Number (PAN), signature, email address, date of birth, gender, photograph (selfie), communication and residential address details. We may also require You to provide additional information such as proof of address to facilitate in evaluation of Your credit profile and creditworthiness by the financial institutions offering or proposing to offer financial products to You. In addition to the above information, We may also collect Aadhaar data (including pictures of Aadhaar), date of birth, PAN details, signature, location and also take Your live video or live selfie photo at the time of sign up for verification purposes. We may also collect other related information such as the date and time of contact with You, the number of attempts and Your availability, for the said verification. The information collected in the course of Your verification shall solely be used for completing KYC procedures and authenticating Your transactions on the Platform. The act of providing Your Aadhaar data is voluntary in nature and the Company hereby agree and acknowledge that they will collect, use, and store such details in compliance with applicable laws and this Privacy Policy.

  1. Financial Information:  We may also ask You for certain financial information, including Your bank account details and type, Indian financial system code (IFSC) of bank, and/or other necessary payment related details or other payment method data, and debit instructions or other standing instructions including NACH mandate to process the Services, including facilitating disbursement and repayments towards the availed financial products through the Platform. We may also use such financial information provided by You, for processing any cashbacks or other rewards offered by Us. We may ask You to provide certain additional information about Yourself on a case-to-case basis. All information disclosed by You shall be deemed to be disclosed willingly and without any coercion. No liability pertaining to the authenticity / genuineness / misrepresentation / fraud / negligence of the information disclosed shall lie on the Company nor will the Company be in any way responsible to verify any information obtained from You.

  1. Details with respect to the financial product availed by You:  We collect information from the financial institution, with respect to the financial product provided by the financial institutions to You, through the Platform, such as amount disbursed by the financial institution, the repayment schedule, the amount repaid, the outstanding amount and other details, for the purpose of providing a summary of same to You on the Platform, and for other purposes in relation to providing the Services on the Platform.

  1. Credit rating related information:  We may require You to share Your credit report for the purpose of verification of Your credit rating and credit worthiness, as required by the financial institution for providing the financial product. We may also receive information in relation to the parameters of credit report, from the financial institution.

  1. KYC related information:  We may retrieve from Your records available with third party including from Know Your Customer (KYC) Registration Agency (KRA) such as name, KYC details, KYC status, father’s/spouse’s name, occupation, address details, CKYC and e-KYC related documents and details and other related documents, for completion of Your KYC, which is required by the financial institutions for processing of Your application for availing a financial product.

  1. Location based information:  When and if You download and/or use the Platform through Your mobile and avail the Services, We explicitly seek permissions from You to get the required information from the device. We may receive information about Your location, Your IP address, and/or Your mobile device, including a unique identifier number for Your device and such other information as may be required by the financial institution for verifying your address (through a one-time permission to access and process such information at the time of onboarding and KYC collection). In addition to the above, We identify and use Your IP address to also help diagnose problems with Our server, resolve such problems and administer the Platform. Your IP address is also used to help identify You and to gather broad demographic information.

The above information is collectively referred to as (“Personal Information”).

  1. One-time Access to Mobile Phone Resources:  As a part of facilitation of the KYC process, We require a one-time access to Your camera to enable You to initiate Your KYC process. We require a one-time access to Your camera to scan and capture the required KYC documents thereby allowing Us to auto-fill relevant fields. This permission allows Us or Our authorized agents to perform Your video KYC while also taking screenshots of Your original officially verified documents that You present during Your video KYC. Video KYC enables You to complete Your KYC digitally, smoothly, and efficiently. Your video shall be recorded and retained for regulatory purposes along with the screenshots of original official verified documents. We require a one-time microphone permission to enable a two-way communication between Our authorized agent and You for the purpose of performing and completing Your video KYC. Your audio shall be recorded for regulatory purposes. We also require a one-time access to Your camera to collect Your selfie, for purpose of KYC process. Additionally, We require access to storage so that Your KYC and other relevant documents stored on Your phone can be accessed for the purpose of the KYC. You can then easily upload the correct KYC related documents, from your phone storage, for faster financial product application details filling and disbursal process. This ensures that You are provided with a seamless experience while using the Platform. This is a one-time request and the same would be obtained while availing the Services.

  1. Non–Personal and Automatic Information:  We may also collect certain non-personal information, such as system generated user ID and access tokens (“Non-Personal Information”), while You browse, access or use the Platform, Services or have the OkCredit App installed on your mobile device. We receive Non–Personal Information by the use of data collection devices such as “cookies” on certain pages of the Platform, in order to help and analyze Our web - page flow, track user trends, and promote trust and safety. We place both permanent and temporary cookies in Your computer’s hard drive.

  1. User communications:  If You choose to post messages on Our message boards, chat rooms or other message areas or leave feedback, We will collect and store such information You provide to Us. We retain this information as necessary to resolve disputes, provide customer support, respond to queries, and inquires, and troubleshoot problems and improve the Services. If You send Us correspondence, such as emails or letters, or if other users or third parties send Us correspondence about Your activities or postings on the Platform, We may collect and retain such information into a file specific to You for responding to Your request and addressing concerns in relation to Your use of the Platform.

All information gathered by the Company shall be stored on servers, log files and any other storage system owned by the Company or by third parties in India, and such storage will be need-based and to the extent required to render Services and for such other purposes as specified in this Privacy Policy.

Our primary goal in doing so is to provide You a safe, efficient, smooth, and customized experience on the Platform. The information collected allows Us to provide the Services and features on the Platform that most likely meet Your needs, and to customize the Platform to make Your experience safer and easier. More importantly, while doing so, We collect the above - mentioned Personal Information from You that We consider necessary for achieving this purpose.

We also use cookies to allow You to enter Your password less frequently during a session on the Platform. Most cookies are “session cookies,” meaning that they are automatically deleted from Your hard drive at the end of a session. You are always free to decline Our cookies if Your browser permits, although in that case, You may not be able to use certain features or Services being provided on the Platform or You may be required to re-enter Your password each time you log – in or access the Platform during a session.

In general, You can browse the Platform without telling Us who You are or revealing any Personal Information about Yourself. In such a case, We will only collect and store the Non – Personal Information. Once You give us Your Personal Information, You are not anonymous to Us. Wherever possible, while providing the information to Us, We indicate which fields are mandatory and which fields are optional for You. You always have the option to not provide the Personal Information to Us through the Platform by choosing to not use a particular Service or feature being provided by Us on the Platform, which requires You to provide such information. We may automatically track certain information about You based upon Your behaviour on the Platform. We use this information to do internal research on Your demographics, interests, and behaviour to better understand, protect and serve You. This information is compiled and analyzed by the Company on an aggregated basis and not individually, in a manner that does not specifically identify You.

You acknowledge that if We determine that any information You have provided or uploaded violates the terms of this Privacy Policy, We have the right, in Our absolute discretion, to delete or destroy such information without incurring any liability to You.

  1. Use of information:

We use the Personal Information, other information and Non-Personal Information, for the following: (i) to provide and improve the Services and features on the Platform that You request; (ii) to resolve disputes and troubleshoot problems; (iii) to help promote a safe service on the Platform and protect the security and integrity of the Platform, the Services and the users; (iv) to inform You about online and offline offers, products, services, and updates; (v) to customize Your experience on the Platform or share marketing material with You; (vi) to detect, prevent and protect Us from any errors, fraud and other criminal or prohibited activity on the Platform; (vii) to enforce and inform about Our terms and conditions; (viii) to process and fulfil Your request for Services or respond to Your comments, and queries on the Platform; (ix) to contact You; (x) to allow Our business partners including partnered financial institutions and/or associates to present customized messages to You; (xi) to communicate important notices or changes in the Services provided by the Company, use of the Platform and the terms which govern the relationship between You and Us; and (xii) for any other purpose after obtaining Your consent at the time of collection.

You also specifically agree and consent to Us collecting, transferring, and sharing information (including Personal Information) related to You with third parties such as with entities registered under applicable laws, with payment gateways/collecting banks/KRAs etc., third parties providing services to Us or to the financial institution, solely for providing Services to You including processing Your transaction requests for the Services. The list of third parties with whom We share Your information is available at Third Party Partners. We will take Your specific consent in case We wish to share Your information with any other third party and update the aforementioned list.

  1. Access and Sharing of Information:

Access to Your Personal Information will be provided to certain of Our employees strictly on a need-to-know basis. We may also disclose Your Personal Information to third party vendors, partnered financial institutions, consultants, and other service providers who work for the Company or provide Services through the Platform and are bound by contractual obligations to keep such Personal Information confidential and use it only for the purposes for which We disclose it to them. You agree and explicitly consent to disclosure of Your Personal Information to such third-parties. This disclosure may be required for Us, for instance, to provide You access to Our Services including for undertaking credit assessment by the partnered financial institutions, processing loan or line of credit or any other financial product related applications by the partnered financial institutions, and processing payments including validation of Your bank accounts and Account information, to facilitate and assist Our marketing and advertising activities/initiatives, for undertaking auditing or data analysis, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to Our Services. We do not disclose Your Personal Information to third parties for their marketing and advertising purposes without Your explicit consent.

The Company may disclose Your information, to the extent necessary: (i) to comply with applicable laws and to respond to lawful requests and legal process, (ii) to protect the rights and property of the Company, Our users, and others, including to enforce the Terms, and (iii) in an emergency to protect the personal safety and assets of the Company, the users, or any person. In such an event the Company is in no manner responsible for informing You or seeking Your approval or consent.

We may, in compliance with applicable laws, share/transfer/assign all of Your Personal Information and other information with any other business entity(ies), in the event of a merger, sale, re-organization, amalgamation, joint ventures, assignment, restructuring of business or transfer or disposition of all or any portion of Our business.

  1. Security Precautions and Measures:

Our Platform has reasonable security measures and safeguards in place to protect Your privacy and Personal Information from loss, misuse, unauthorized access, disclosure, destruction, and alteration of the information in compliance with applicable laws. Further, whenever You change or access Your Account on the Platform or any information relating to it, We offer the use of a secure server. We cannot however ensure or warrant the security of any information You transmit to the Company or guarantee that Your Personal Information and/or other Non-Personal Information provided for availing the Services or Platform may not be accessed, disclosed, altered, or destroyed by a breach of any of Our security measures and safeguards. In the event of any actual or suspected security incident, including data breach, We will take all measures required to be undertaken under applicable laws. It is further clarified that You have and so long as You access and/or use the Platform (directly or indirectly) the obligation to ensure that You shall at all times take adequate physical, managerial, and technical safeguards, at Your end, to preserve the integrity and security of Your data which shall include and not be limited to Your Personal Information.

This Privacy Policy and the security controls and practices implemented by the Company to protect Your Personal Information shall be the reasonable security practices and procedures under Section 43A of the Information Technology Act, 2000. Further, We shall also ensure compliance with various technology standards/requirements on cybersecurity stipulated under applicable laws, in provision of Our Services to You.

  1. Links to Other Third – party Sites and collection of information:

Our Platform may provide links to other third - party Platforms (“Third – Party Sites”) that may collect Your Personal Information including Your IP address, browser specification, or operating system. The Company is not in any manner responsible for the security of such information or their privacy practices or content of those Third – Party Sites. Additionally, You may also encounter “cookies” or other similar devices on certain pages of the Third – Party Sites and it is hereby clarified by the Company that it does not control the use of cookies by these Third – Party Sites. These third-party service providers and Third-Party Sites may have their own privacy policies governing the storage and retention of Your information that You may be subject to. This Privacy Policy does not govern any information provided to, stored on, or used by these third-party providers and Third-Party Sites. We recommend that when You enter a Third-Party Site, You review the Third-Party Site’s privacy policy as it relates to safeguarding of Your information. You agree and acknowledge that We are not liable for the information published in search results or by any Third-Party Sites.

  1. Public Posts:

You may provide Your feedback, reviews, testimonials, etc. on the Platform on Your use of the Services provided by the Company (“Posts”). Any content or Personal Information and Posts that You share or upload on the publicly viewable portion of the Platform (on discussion boards, in messages and chat areas, etc.) will be publicly available, and can be viewed by other users. Your Posts shall have to comply with the conditions relating to Use of Platform as mentioned in the Terms. The Company retains an unconditional right to remove and delete any Post or such part of the Post that, in the opinion of the Company, does not comply with the conditions in the Terms. The Company reserves the right to use, reproduce and share Your Posts for any purpose. If You delete Your Posts from the Platform, copies of such Posts may remain viewable in archived pages, or such Posts may have been copied or stored by other Users.

  1. Your Consent and Changes to Privacy Policy:

Withdrawal of consent: You may choose to withdraw Your consent (including regarding processing of data by Us or by any third party or regarding data retention) provided hereunder at any point in time. Such withdrawal of the consent must be sent in writing to help@okcredit.in. In such a scenario, the Company may delete Your information (personal or otherwise) or de-identify it so that it is anonymous and not attributable to You. However, revocation of consent shall not impact the processing of the data undertaken by the Company prior to such revocation. In case You do not provide Your consent or later withdraw Your consent, We request You not to access the Platform and use the Services and also reserve the right to not provide You any Services on the Platform.

Correcting inaccuracies in the information: You may correct or update any information online. In the event of loss of access details, You may retrieve the same or receive new access details by sending an e-mail to: help@okcredit.in.

Right to Erasure: This is also known as ‘the right to be forgotten’ and, in simple terms, enables You to request the deletion or removal of Your Personal Information where there’s no compelling reason for Us to keep it. Such right of erasure can be exercised by writing to Us at help@okcredit.in. This is not a general right to erasure; there are exceptions, such as when the law requires Us to retain certain personal information about You or where such retention is required for providing Our services to You, etc.

Changes To Our Privacy Policy: We reserve the unconditional right to change, modify, add, or remove portions of this Privacy Policy at any time, by notifying You of such changes. Any changes or updates will be effective immediately. You should review this Privacy Policy regularly for changes. You can determine if changes have been made by checking the “Last Updated” legend above.

  1. Data Retention and Deletion

We shall be entitled to retain Your Personal Information and other information for such duration as may be required for the purposes specified hereunder or for such other periods as may be required under the applicable laws and the said information will be used by Us only in accordance with this Privacy Policy. Notwithstanding anything contained herein, We will not retain your Personal Information and other information for longer than the periods provided below.

Type of Data

Data Retention Period

Information You give Us

End of Your relationship with Us + 3 years  

Financial Information

End of Your relationship with Us + 3 years  

Details with respect to the financial product availed by You

End of Your relationship with Us + 3 years  

Credit rating related information

End of Your relationship with Us + 3 years  

KYC-related information

End of Your relationship with Us + 3 years

Location based information

End of Your relationship with Us + 3 years

Information generated through one-time access to SMS, camera and microphone

End of Your relationship with Us + 3 years  

Information generated through one-time access to storage

End of Your relationship with Us + 3 years

Non-personal and Automatic Information

As required under applicable laws

User Communications

End of Your relationship with Us + 3 years

However, We may retain information related to You if We believe it may be necessary to prevent fraud or future abuse, to enable Us to exercise Our legal rights and/or defend against legal claims or if required by law or for other legitimate purposes. When the retention period for Your Personal Information, information generated through one-time access to SMS, camera and microphone as outlined above expires, We will actively destroy/delete such Personal Information and other information from Our systems.

We will comply with the following procedure for destruction and disposal of Your Personal Information and other information:

  1. IT department is responsible for deleting or destroying electronic records. This includes ensuring that the Personal Information and other information is permanently removed and from company system and destroyed.

  1. No Personal Information and other information that are currently involved in, or have open investigations, audits, or litigation pending shall be destroyed or otherwise discarded.

  1. When retention requirements have been met, Personal Information and other information shall be immediately destroyed.

  1. The authorized methods of destruction for non-electronic Personal Information and other information are shredding

We may, however, continue to retain Your Personal Information in anonymized form for analytical and research purposes.

  1. Grievance Officer:

If You have any grievance with respect to the Platform or the Services, You may write to the grievance officer, the name and contact details have been provided below:

Name : Jayanth Bhatt

Email : help@okcredit.in  

Address : Incubex HQ · 339, 14th B Cross Rd Sector 6, HSR Layout, Bengaluru, Karnataka 560102, India

  1. Questions:

Please feel free to contact Us at help@okcredit.in regarding any questions on the Privacy Policy.