Privacy Policy - Daga Mercantiles & Finance Pvt Ltd

1. Overview

Daga Mercantiles & Finance Private Limited (a Non-Banking Financial Company registered with and regulated by the Reserve Bank of India, hereinafter referred to as "we," "our," or "Daga Mercantiles & Finance Private Limited") values your privacy and the protection of your personal information. This Privacy Policy (hereinafter referred to as "this Policy") describes how we collect, use, process, store, protect, and disclose your personal information when you use our personal loan application "ReliLoan" (hereinafter referred to as the "App") and related financial services (hereinafter referred to as the "Services").

We are committed to processing your personal data in a lawful, fair, and transparent manner, in accordance with the India Digital Personal Data Protection Act, 2023 and its associated rules (hereinafter referred to as "DPDPA"), as well as applicable guidelines issued by the Reserve Bank of India. Please read and understand the entire content of this Policy before using our Services. If you disagree with any terms of this Policy, please cease using our App and Services immediately. Your continued use of the Services constitutes your acceptance of the terms described in this Policy.

2. Personal Information We Collect

To provide you with loan services, fulfill contractual obligations, and comply with legal requirements, we may collect the following categories of personal information:

a. Identity and Contact Information:

This includes your name, date of birth, gender, details or images of official identity documents (such as Aadhaar Card, PAN Card), email address, mobile number, marital status, education level, number of children, etc.

b. Employment Information:

This includes your employment status, type of employment, salary day, personal income and expenses, employer information, etc.

c. Financial Information:

This includes household income, household expenses, personal income, personal expenses, etc.

d. Device Permissions and Corresponding Information:

i. Camera:

To ensure your account security and facilitate smooth identity verification, we will access your camera permission upon your explicit consent. This permission is used solely for capturing images of your identity documents or for facial recognition to confirm you are the legitimate account holder. We commit to using this permission only when necessary and strictly protecting your biometric information.

ii. Location Information:

To confirm your location and for risk management purposes, we will access your precise or approximate location information upon your explicit consent. This permission is used primarily to verify that you are within India (we currently do not provide services to users outside India) and to assist in fraud prevention analysis. We commit to requesting this permission only when necessary.

iii. Contacts:

To optimize your loan experience, we will access your contacts permission upon your explicit consent. This permission is used solely to help you quickly add emergency contacts and shorten the loan application process. We commit to strictly protecting the privacy of all contacts in your list and will only collect the information of contacts you specifically select.

iv. Advertising Identifier:

To provide you with more personalized loan service recommendations and improve your user experience, we may collect and use your advertising identifier (e.g., IDFA) upon your consent. This information is used solely for analyzing service usage within the App to enable precise feature and content optimization. You can disable this permission at any time in your device settings.

3. How We Use Your Information

We process your personal information only for the following explicitly stated purposes:

To provide and process loan services: assessing your loan application, determining your credit limit, approving and disbursing loans, managing your account, and handling repayments.

For identity verification and KYC compliance: verifying your identity and completing the 'Know Your Customer' process as required by the Reserve Bank of India and the DPDPA.

For credit assessment and risk control: evaluating your creditworthiness and repayment capacity, and conducting ongoing risk management to detect, prevent, and combat fraud.

For customer service and communication: contacting you regarding your account, transactions, or our Services, and responding to your inquiries and requests.

To fulfill legal and regulatory obligations: complying with Indian laws and regulations, including but not limited to anti-money laundering regulations, tax reporting requirements, and the provisions of the DPDPA.

For service improvement and research & development: analyzing how users interact with our Services after anonymization to improve the App's functionality, security, and user experience.

For marketing and promotion: recommending other financial products or services we believe may interest you, subject to your separate consent. You have the right to opt-out of such marketing communications at any time.

4. How We Share and Disclose Your Information

We are committed to keeping your information confidential. However, we may share your information with third parties under the following circumstances to provide the Services and comply with the law:

a. Credit Information Companies:

We legally report your loan account performance and credit history to Indian credit information companies (such as CIBIL, Equifax, Experian, and CRIF High Mark).

b. Banking and Payment Partners:

To facilitate loan disbursement and repayment deductions, we share necessary information with your designated bank and our payment processing partners. As per RBI regulations, payment data is stored within India.

c. Technology Service Providers:

We may provide information to trusted third parties who provide technical support to us (e.g., cloud service providers, data analytics services). These providers are bound by strict confidentiality agreements and may only process data on our instructions.

d. Legal and Regulatory Authorities:

We may disclose your information in response to court orders, government requests, or to comply with applicable law.

e. With Your Explicit Consent:

We may share your information with other parties upon obtaining your specific and separate authorization.

5. Cross-Border Data Transfers

Pursuant to the DPDPA, the Indian government may specify a list of countries to which personal data can be transferred. In compliance with the Act, we may transfer and store your personal data outside India. When conducting such transfers, we will ensure an adequate level of protection. Please note that the specific provisions of the DPDPA regarding cross-border data transfers are not yet fully in force, and we will closely monitor developments to ensure full compliance.

6. Data Security Protection Measures

We implement administrative, technical, and physical security measures aligned with industry standards to protect your personal information from unauthorized access, alteration, disclosure, or destruction. These measures include data encryption, access controls, security audits, and employee training. Please be aware that no method of internet transmission or electronic storage is 100% secure.

7. Data Retention Period

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Policy, or as required by your agreement with us and applicable laws (such as the DPDPA, RBI guidelines, and tax laws). Once the retention period expires, we will securely delete or anonymize your personal data.

8. Your Data Subject Rights

a. Under the DPDPA, you have the following rights regarding your personal data:

A. Right to Access:

You have the right to request access to the personal data we hold about you.

b. Right to Correction and Erasure:

You have the right to request the correction of inaccurate or incomplete personal data, and to request the erasure of your personal data under specific conditions.

c. Right to Withdraw Consent:

You have the right to withdraw consent previously granted for the processing of your personal data. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

d. Right to Grievance Redressal:

If you have any grievances about how we process your personal data, you have the right to raise them with the designated grievance redressal officer (such as the Data Protection Board of India).

You may exercise these rights by contacting us using the details provided in the "How to Contact Us" section of this Policy.

9. Cookies and Tracking Technologies

Our App may use cookies and similar tracking technologies to enhance your user experience, such as remembering your preferences, analyzing App usage, and providing personalized content. You can manage your cookie preferences through your device or browser settings.

10. Updates to This Policy

We may update this Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any significant changes by placing a prominent notice in the App or by contacting you directly using the details you have provided. We encourage you to review this Policy periodically for the latest information.

11. How to Contact Us

If you have any questions, comments, concerns, or complaints regarding this Privacy Policy, your personal information, or your data rights, please contact our Grievance Officer using the following details:

a. Company Name: Daga Mercantiles & Finance Private Limited (RBI Registered NBFC)

b. Customer Support Email: info@dagafin.com

c. Grievance Officer Email: venkatesh@dagafin.com

d. Registered Office Address: 15/5/6 Olabibitala 1st Bye Lane Lp-480/7, Howrah, 711104 IN

We will endeavor to investigate and resolve your concerns within a reasonable timeframe.