PRIVACY AND SECURITY POLICY

1. INTRODUCTION

This privacy and security policy (“ Privacy Policy”) establishes the Terms and Conditions under which Finxer Technologies Private Limited (“ the Company” or “ Capital Now” or “ we” or “ us” or “ our”), processes the personal information that you provide us with when using the website “www.capitalnow.in” (“ the Website” or “ site”), the mobile application or app “ CapitalNow.in”, understood as the software application designed to be used on smartphones, tablets or other mobile devices (“ App”) or other applications, software, digital media, storage medium, or functionalities related to our brand (collectively referred to as “ Platform”).
Capital Now has developed the Platform through which you may apply for a loan to be granted by various non-banking financial companies or banks (“ Lender” or “ Lending Partner”), based on the loan agreement to be executed between you and the Lender. The Lender has further appointed and authorized us to collect, store, authenticate, verify and distribute the Personal Information (as defined below) as may be required by the Lender to sanction and disburse the loan.
Maintaining the security of your data is a priority at Capital Now. We are committed to respecting your privacy rights. We pledge to handle your data fairly and legally at all times. We are also dedicated to being transparent about what data we collect about you and how we use it. By visiting and accessing the Platform and availing the loan facilitation services provided by us, you are deemed to have read, acknowledged and accepted all the provisions stated here in the Privacy Policy, including any changes we may make from time to time.

If you do not agree to this Privacy Policy or any part thereof, please do not use/ access/ download or install the Platform or any part thereof.

The Platform is not expected to be used by any person below 21 years of age and should be an Indian national.

This Privacy Policy provides you with information about:

2. WHAT PERSONAL INFORMATION WE COLLECT

We collect, transmit, and store personal data about you on our secured capital now server (https://api.capitalnow.in) after obtaining your consent, to provide you with, or in connection with, the Services. Please note that we only collect and process a minimal amount of your personal data to provide you with the Services. Such personal data includes:

Personal Information: This includes your first and last name, date of birth, gender, photographs, educational qualifications, purpose of loan, house ownership, employment status, company name, contact information (including addresses, email IDs and phone numbers) and marital status.
This information is a part of the registration process and helps to communicate with you for the loan application process.

1. Financial and KYC Information: We, our Lending Partner collect the data you provide to us when you accept the tentative terms of the loans. This includes your photograph, Aadhaar Number, PAN, parents’ names, bank account number, IFSC, proof of address (which can be your electricity bill, rental/lease agreement, gas bill, passport or driver’s license, or any other document our App may be able to record).
   How we use this data: See, For Enabling the App and its Services; For Loan Processing and KYC Authentication Partner and; For Legal Compliance and Requirements.
2. Location: We collect and monitor the information about the location of your device to check serviceability of your loan application, prevent fraudulent activity and also provide customized loan offers.
3. Camera Access: We require access to Your mobile device camera for a seamless experience for clicking Your selfie and to upload photos for Your KYC compliance and/or for uploading any other necessary documents on the Portal. User image, for us to cross check and verify the authenticity of the User and for prevention of fraud.
4. Social Media: We collect your public profile data depending on the social media or networking platform used like Facebook/LinkedIn etc. to login to our Platform. The information collected from your social media networking account shall be clearly displayed to you at the time of login to our Platform.
5. Device information: We collect the unique device identifiers like serial numbers to uniquely identify the device to ensure that unauthorized devices are not able to act on your behalf and to mitigate fraud.
6. Credit information: We may collect information related to your credit from third parties (under lawful contracts).
7. Financial information: We may collect information related to your transactions on the Platform such as loan details, transaction history, repayment details.
8. Log information: We may collect information related to your use of certain functions. For example, cookies and other anonymous identifier technologies, IP addresses, network request information, temporary message history, standard system logs, and crash information.


3. INFORMATION YOU PROVIDE US ABOUT YOURSELF:

Information you provide to us or upload on our Platform including your information related to education, occupation, account details, identification documents, banking information such as salary slips, bank statements, PAN card, bank account number, payment information, or any other information/documents for KYC compliance and loan application process.
This list is not exhaustive and in specific instances you may need to provide additional data for the purposes mentioned/outlined in this Privacy Policy. However, one time access may be required for camera, microphone, location or any other facility necessary for the purpose of on-boarding/ KYC requirements.
You may also be required to provide other types of Personal Information in exceptional circumstances only. If we do need to process additional types of Personal Information about you, we will make sure that you are informed about the processing and that there is a valid legal basis for doing so (e.g. your consent).

1. Please bear in mind that before availing any services on the Platform, you must read this Privacy Policy. You may choose not to provide certain Personal Information or withdraw the consent or ask us to delete such information collected or restrict disclosure to third parties subsequently with respect to such Personal Information by sending a written intimation. However, not providing certain compulsory information or withdrawing the consent may mean that it will not be possible to manage your registration as a user or to use certain functionalities available through the Platform.
2. You hereby guarantee that the Personal Information provided is true and exact, and agree to report any change or modification thereto. If you provide us with the Personal Information of third parties, you shall be responsible for having informed them and obtained their consent for these details to be provided for the purposes indicated in the corresponding provisions of this Privacy Policy. Any loss or damage caused to the Platform, to Company or to any third party through the communication of erroneous, inaccurate or incomplete information on the registration forms shall be your sole responsibility.
3. The Personal Information provided by you will be collected and retained, on behalf of our Lending Partner.
4. You hereby consent that we may process and disclose Personal Information to our Lending Partners, our affiliates, third party service providers and credit bureaus for the purposes stated in this Privacy Policy and as per applicable laws.
4. THE COMPANY SHALL USE THE PERSONAL INFORMATION FOR THE FOLLOWING PURPOSES:
1. Loan Facilities: Providing loan facilitation services to you, and legal compliance on our part under applicable laws.
2. Improved Services: Providing, processing, maintaining, improving and developing the Platform and our services to you, including customer support functions. Analyzing statistical information about the use of the Platform to improve our services.
3. Application Updates: Contacting you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as the App's push notifications etc., regarding updates or informative communications related to the functionalities, contracted services, including Platform security updates, when necessary or reasonable for their implementation.
4. Marketing:Conducting marketing related activities, such as providing marketing and promotional materials.
5. Setting up your own Platform account. Personal Information, collected when creating a Platform account on our Platform or through your device, is used for creating the personal Platform account of the user.
6. Identifying devices. Device related information and application related information may be used to identify devices when you use the Platform.
7. Verifying user identity. The Platform uses your Personal Information to verify the user identity including your mobile number and/ or email address, (if any), through one time password (“OTP”) and to ensure that there is no log-in by any unauthorized persons.
8. Managing risks and conducting anti-fraud checks. Device related information as well as your location and user information may be used to control risk, detect fraud and provide better services to you.
9. Diagnosing service failures. Log information may be used to help diagnose service or technical problems and maintain security.
10. Collecting user feedback. The feedback you choose to provide is valuable in helping the Platform make improvements to our services. In order to follow up on the feedback that you choose to provide, the Platform may correspond with you using the Personal Information that you have provided and may keep records of the same.
11. Sending notices. From time to time, we may use your Personal Information to send important notices, such as communications about changes to our terms, conditions and policies.
5. WE MAY DISCLOSE YOUR PERSONAL INFORMATION:
1. to companies that are affiliated with us.
2. to the Lender. We contract with Lender to facilitate the provisioning of loan services offered by such Lender to you on the Platform. We will only disclose such information to the Lender that is necessary for you to use the Platform and transact with the Lender and to the extent the Lender requires such information to assess your suitability for a loan, grant a loan to you, or otherwise transact with you.
3. to third-party service providers who provide services to CapitalNow, such as website hosting, data analysis, payment processing, infrastructure provision, information technology services, due-diligence, customer service, e-mail delivery services, credit card processing, auditing, training, and other similar services. (These third parties will be supplied with, or have access to, your Personal Information for the purpose of providing these services to us or on our behalf).
4. to the administrators. We might provide your Personal Information to our management team or administration department to enhance your experience with us and assist you 24*7.
5. to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
6. as we believe necessary or appropriate: (i) under applicable law, including laws outside your country of residence; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (iv) to enforce Terms and Conditions of the Platform; (v) to credit information companies (vi) to protect our operations or those of any of our affiliates; (vii) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (viii) to allow us to pursue available remedies or limit the damages that we may sustain.
6. DATA PROTECTION & SECURITY
1. All your Personal Information is stored on secure servers that are protected in controlled facilities situated in India. We shall only store basic personal information such as name, address, contact information etc. which are required to be stored for carrying out our services. For other personal information collected as part of our services being provided to the Lending Partners, we shall collect such information upon the instructions of the Lending Partners and thereafter transfer the same to the Lending Partners upon the completion of the preliminary onboarding. We classify your data based on importance and sensitivity, and ensure that your Personal Information has the highest security level. We maintain appropriate technical and organizational security safeguards designed to protect the Personal Information we process against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use including adopting reasonable security practices and procedures comprising of managerial, technical, operational and physical security control measures as mandated under applicable Indian laws for the protection of Personal Information and to prevent unauthorised use or disclosure of Personal Information.
2. When you send or receive data from your device to our servers, we make sure they are encrypted using Secure Sockets Layer (“ SSL”) and other algorithms.
3. We will take all practicable steps to safeguard your Personal Information. However, you should be aware that the use of the internet is not entirely secure, and for this reason we cannot guarantee the security or integrity of any Personal Information which is transferred from you or to you via the internet.
7. HOW LONG WE RETAIN PERSONAL INFORMATION
1. Personal Information will be held for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. We shall cease to retain Personal Information, or remove the means by which the Personal Information can be associated with particular individuals, as soon as it is reasonable to assume that the purpose for which that Personal Information was collected is no longer being served by retention of the Personal Information, and there being no outstanding payment obligations of you towards the Lender. In accordance with the applicable KYC norms in India, the data relating to KYC is required to be retained for a stipulated time period. Accordingly, as per the applicable law, we will be retaining all documents and information relating to your KYC.
8. UPDATES TO THE PRIVACY POLICY
1. We keep our Privacy Policy under regular review and may update this Privacy Policy to reflect changes to our information practices. If we make any changes to our Privacy Policy, we will post the changes on the Platform so that you may be aware of the information we collect and how we use it. Such changes to our Privacy Policy shall apply from the effective date as set out in the notice or on the website. Your continued use of services on the Platform will be taken as acceptance of the updated Privacy Policy.
9. TERMS AND CONDITIONS OF PLATFORM
1. If you choose to avail services at our Platform, your transaction and any dispute over privacy is subject to this Privacy Policy and our Terms and Conditions of Platform, including limitations on damages, resolution of disputes, and application of the prevailing law in India. If you have any concern about privacy at CapitalNow, please contact us with a thorough description, and we will try to resolve it. If you are found to be in non-compliance with laws and regulations, the Terms and Conditions published on the Platform, or this Privacy Policy, CapitalNow shall have the right to immediately block your access and usage of the Platform and Capital Now shall have the right to remove any non-compliant content and/or information forthwith, uploaded by you and shall further have the right to take appropriate recourse to such remedies as would be available to it under various statutes.
10. YOUR RIGHTS
1. Your rights under applicable law may include access to the Personal Information we process about you, the right to have such Personal Information corrected, updated or erased, the right to restrict the processing of your Personal Information, as well as the right to data portability. Where we have obtained your consent for the processing of your Personal Information, you have the right to withdraw your consent at any time. This will not affect the lawfulness of the processing that has happened based on your consent prior to the withdrawal. To exercise these rights, you should make a written request using our contact details set out below and it may result in suspension or termination of our services being provided to you.
2. You also have the right to object, at any time, to the processing of your Personal Information which is based on CapitalNow’s legitimate interests. Further, if you wish to remove all your Personal Information from the Platform, you can do so by opting out of the Platform and uninstalling the Platform from your system(s).
3. You shall have the right to request deletion of your account by verifying your mobile number through OTP. We have a simple and straightforward process which is fair as well as consistent, for account deletion, and provide clear communication, confirming or cancelling your account deletion request and ensuring you're informed every step of the way. As regards your data, it is handled with utmost care and precision, and we make it easy for you to regain access to the same within 30 days if you change your mind. Our process for account deletion is designed with your privacy in mind. When it comes to account deletion, we understand the importance of safeguarding your personal & financial information. At Capital Now, we take the privacy of our users seriously. Our commitment to data safety and responsible information management is unwavering.
11. GOVERNING STATUTE
1. This Privacy Policy is governed by and is compliant with the applicable laws of India, in order to protect Personal Information of the end-user(s) of the services.
12. GRIEVANCE OFFICER
1. If you have any comments or inquiries about this Privacy Policy or if you would like to update information we have about you, or to exercise your rights, you may contact our Grievance Officer,

Name: Vennela kakaraparthi

E-mail Address: support@capitalnow.in

Office Address: Orbit, 8th Floor, Symbyont Smart Spaces, Plot no. 30/C, Sy. no. 83/1, Raidurg, Serillingampally Mandal, Hyderabad, Telangana- 500019

13. COOKIES
Our Platform uses cookies. A cookie is a small text file, which is stored on your computer, mobile phone, tablets etc. in order to recognize your computer at recurring visits. The cookie may transmit information via your browser with a purpose of authenticating or identifying the computer (via e.g. the IP address) or the user. Cookies may contain information such as registration data and user preferences. When a server receives a request from a computer which stores a cookie from the website, the server is able to use the information stored in the cookie in combination with the information stored on the server. To learn more about cookies, please visit the following site, which is not affiliated with CapitalNow: http://www.allaboutcookies.org/.

Last updated on : 01-DEC-2023