This documentation is on the Privacy Policy under the provisions of Rule 4 (1) of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011. It requires the privacy policy to publish your personal information to deal with it and handle it. It includes private data and information that can be sensitive. When you go to the website, www.cliktoloan.com or the cliktoloan mobile or web application collectively, the Platform and use these services provided by us (Services), you will agree on the terms and conditions of this Privacy Policy. By accessing the Platform or any part thereof, you must signify your assent to this Privacy Policy. You must also consent to the processing of your private data and information (Personal Information, Sensitive Personal Data, or Information) to X10Financial Services Limited. This Privacy Policy is incorporated within and subject to the Terms of Use of the Platform. For this Privacy Policy, the Service users may be consumers, customers, buyers, or any other person using these Services or accessing our Platform. If you do not agree to this Policy or any part of it, please do not use, access, download, or install the Platform.

ASSORTMENT OF USER PERSONAL INFORMATION

When you utilize our Platform, we gather and store the data given by you from time to time by looking for authorizations from YOU to get the necessary data. Our main objective for which we are doing this is to provide you a protected, productive, smooth, and customized insight and Services. It permits us to offer your assistance and features that address your issues and customize our Platform to make your experience more secure and easy, and improve the Services given by us. More significantly, we gather personal data from you that we consider essential for accomplishing the purpose mentioned previously. All in all, you can peruse the Website or App without disclosing to us what your identity is or revealing any data about yourself. Further, for making an account on the Platform, you should give us some essential data needed for customized services. The data we gather from you, entomb Alia, contains:
  • Your complete name
  • Gender
  • Email address
  • Photos
  • Mail address
  • Postal code
  • Family information
  • College/university details
  • Contact number
  • Prepaid details of wallet linked
  • Bill details
  • Details of your car
  • Permanent Account Number (PAN)
  • Academic certificates and records.

WHAT WE DO WITH THE INFORMATION WE GATHER

At every possible opportunity, we demonstrate the required and the discretionary fields. You generally have the alternative to not give any data by deciding not to utilize a specific feature or a service on the Platform. We also gather data from your user account. It mainly includes your email address and public profile data like your name, photos, ASID. It depends on the platforms that you are using to sign up for the Website or App.
This data is needed for the registration process to have access to our services. It is also useful for auto-populating the main fields from the course of the interface of the Website or App. We further gather other recognizable data, for example, the history of your transactions on the Platform when you set up a free record with us, as detailed below. While you can search a few sections from our Platform without being an enrolled member, as mentioned earlier, specific activities (for example, benefiting from credits from the lender of the third parties on the Platform) require enlistment and for you to give the above details. The Platform will clearly show the personal data it is gathering from you, and you have the alternative option for not providing your data. In any case, this will restrict the services given to you on the Platform.
This Website will also record your phone number for the verification process and to check the active status of your SIM on the device, remarkably distinguish you, and prevent frauds and unapproved access.
As a part of the Video Know Your Customer (Video KYC) process, collecting your data is mandatory. It guarantees the validation and completion of your KYC. In this manner, the consents of microphones, cameras are a must.

COLLECTION OF FINANCIAL SMS INFORMATION

We do not gather, store, or read your texts from your inbox. Instead, we collect and monitor the financial SMS of 6-digit numbers sent by the alphanumeric senders. It helps us identify the different bank accounts you are holding with the cash flow details, description, and transaction amounts taken by you. It will help us to assess your credit risk. Further, it enables us to determine your profile risk and to give you an appropriate credit analysis. Due to this process, you can take the financial facilities to regulate financial entities available on the Platform. This SMS for financial data also includes your data history. While you are using the application, it often sends your financial text information to us and the associated servers.

COLLECTION OF DEVICE LOCATION AND DEVICE INFORMATION

We gather and monitor the information about the device location to provide the service for loan applications, reduce the risk associated with the loan applications and provide you customized loan offers pre-approved. It helps us to verify your address, make a better decision for your credit risk and know your KYC process as our customer.
The information that the Website or App collects depend on how you manage or control your privacy on your device. After installing the Website or App, we gather pieces of information with unique identifiers attached to your device. Thus, when you download and install the Website or App, we explicitly seek your permission to get the required details needed from your device.
The Website or App collects much information related to your device, for example, its hardware mode, RAM, build model, and storage. Further, it marks the unique device identifiers like its serial number, IMEI, SSAID, and AAID.
Information on SIM, roaming state, network operator, MNC and MCC codes, and your WIFI details, and the mobile network information is also collected. To identify the device location, we collect the MAC address. By gathering this information, we try to prevent unauthorized acts or frauds on your behalf.
Collecting information about your device helps us to provide automatic updates and additional security. That is how we make sure that your account does not get operated by someone else on a different device. Besides, the information collected helps us to get valuable feedback as a device holder. We can also get to know about the device behavior that will help us to improve our services and provide you an enhanced customized user.

COLLECTION OF CONTACT INFORMATION

As a part of the loan journey facilitated by M/s D.pal Leasing & Finance Company Limited, we collect and monitor your information. It includes your name, contact number, modified contact list, favorites, account type, and other optional data. It will enable you to autofill the data during the process of the loan application. This information is also helpful for the risk purpose analysis and enables us to detect your credible references. It also has access to your risk profile and helps us to determine your eligibility for a loan.

COLLECTION OF INSTALLED APPLICATIONS

We will collect a list of metadata information of the installed applications. It includes the name of the application, updated time, package name, time of installation, name of the version, and the version code for each of the applications installed in your device. It is necessary to access your creditworthiness and improve your profile for customized pre-approved loan offers.

CAMERA

We require a camera to scan, access, and capture the essential documents for KYC. It allows us to auto-fill the relevant fields. As a part of the KYC journey to facilitate, we need to have access to your camera to initiate the KYC process. It allows us and our authorized agents to perform your KYC Video and taking screenshots of your original documents that are verified. You need to present these documents during the journey of KYC Video. The KYC Video helps to complete your KYC digitally, smoothly, and carefully. We will record your video held for regulatory reasons alongside the screenshots of your original Official Verified Documents.

MICROPHONE

For enabling a two-way communication process, we require permissions for using a microphone. This communication takes place between you and our agent. It is a must for performing and completing your KYC Video. Further, we will also record your audio for the same regulatory purpose.

STORAGE

For storing your KYC and other relevant documents, we require your permission so that you can safely download and save them on your device. You can also easily upload the right KYC-related documents to create a faster application for the loan process. It also includes the details of files and the disbursement process. It guarantees that you are provided with a smooth experience while you are using the application.

REASON FOR REJECTION LOAN APPLICATION

When you are looking for a loan make sure to eliminate any inaccurate information. Also, multiple loan rejections can increase your chances of negatively affecting your credit score. If your loan application was recently rejected by M/s D.pal Leasing & Finance Limited, then you may need to find out the reasons for the disapproval. The rejection of loan criteria is mentioned in the below points.
  • -Non Operational Area
  • -Non Operation Area in Active Area
  • -Rented house without renewal agreement & huge liabilities
  • -CIBIL Bureau negative, OD & DPDs
  • -CIBIL Bureau negative, OD in recent tracks with high liabilities
  • -Low employment tenure also variations in salary
  • -CIBIL Bureau negative, Suit filed case, OD & very high DPDs in recent tracks including PL
  • -Applicant residing at rented house with his friend not family
  • -Low salary residing tenure in rented house
  • -Community dominated area, negative area
  • -Low salary, high liabilities
  • -Low residing tenure in rented house also low salary
  • -Residing alone in rented house
  • -Applicant residing in brother's flat not able to provide address proof
  • -Low employment tenure, rent agreement not renewal
  • -Poor employment tenure, issue in employment stability
  • -Applicant not okay with ROI
  • -Bank statement edited
  • -CIBIL Negative, high amount of OD & PL written-off
  • -Not responded since long time
  • -No prompt response from customer's side
  • -Not provided current address proof
  • -Customer wants high amount

COLLECTION OF OTHER NON-PERSONAL INFORMATION

We track some pieces of information automatically. This information depends on your behavior within our platforms. With this information, we do internal research on their interests, behaviors, and demographics. It helps us a better understanding and to protect and serve our users and improve our services. This information is combined and used for analysis on an aggregate basis. We also collect your Internet Protocol (IP) address and the URL used by you for connecting your computer to the internet, etc. This information also includes the URL that you came from (whether the URL is from our Websites or not), the URL that you are going next (whether this URL is from our Websites or not), your IP address, and your computer's information on the browser.
The small data files called cookies are usually gets stored by the websites on your computer. We use those cookies on our websites like the other websites or app and online marketplace websites or app. This information helps us to identify you and make our website more convenient and accessible. Many browsers will allow you to decline cookies. If you choose to decline, then it may affect the services of our website.
If you are willing to purchase from the Platform, we will gather data about your purchasing behavior.
We hold this information and use it when necessary for resolving disputes, customer support, and fix the problems as permitted by the law. Any personal correspondence like emails or letters sent by you or by any other third parties regarding your activities or postings on our Website we collect that information in a file meant for you.

USE AND DISCLOSURE OF YOUR PERSONAL AND OTHER INFORMATION

We understand that your personal information is crucial. We ensure you that this information we are using is for intended purposes only. We access, gather, and use the information collected from you under the applicable laws to provide our services. We do research and develop new subjects that are within our limitations to set up our Privacy Policy.
We use the above information for the following reasons:
  • To resolve disputes.
  • To fix problems.
  • Email address
  • Helps to promote a protect assistance.
  • Logical analysis
  • For marketing and promotional purposes like sending you promotional SMS, Email or Whatsapp.
  • To measure buyers' fulfillment and satisfaction from our products and services.
  • To inform you about the online and offline offers, items, services, and updates.
  • To modify your experiences.
  • To detect and secure us from any suspicious or criminal activity, fraud, and any other crimes.
  • To uphold our terms and conditions.
  • To improve our services or that was described to you at the time of collection.
  • With our efforts to consistently improve our goods and services that we offer to you, we gather and examine the profile information about our user's activity from our Platform.

PURPOSE FOR COLLECTION OF INFORMATION

The intended purpose behind gathering your personal information provided by you is because:
  • To establish your behavior and to confirm the same.
  • To encourage your KYC.
  • To improve, monitor, and directing our Platform.
  • To provide our service, for example, performing credit profiling to facilitate loans to You.
  • To design and offer customized goods and services that our third-party financial accomplices offer.
  • To analyze how the Platform gets utilized, analyze service or technical issues, and look for safety measures.
  • To send communications warnings, providing data concerning the various goods or services You have desired, or process questions and applications You have filled on the Platform.
  • To manage our relationship with You and notifying You about various goods and services we think you might find of some use.
  • To conduct information and analyze for improvisation of the goods and services provided to the users.
  • To use the user data to conform with country laws and guidelines.
  • To conduct KYC relevant for our third-party lending partners based on the data shared by the users.
  • To use the user's data in other ways allowed by law to permit You to take monetary services from our lending partners.
  • We will utilize and hold this data for the time being when it becomes necessary to give You the services on the Platform. We will take consent within our legal commitments, solve issues, and implement our arrangements.

THIRD PARTY SITE USAGES

If you click on one of the links to third party websites, you may be taken to websites we do not control. This policy does not apply to the privacy practices of those websites. Read the privacy policy of other websites carefully. We are not responsible for these third-party sites. We are using third party tool for extracting customer CIBIL.

SHARING OF INFORMATION WITH THIRD-PARTIES

Further the Company and our service providers may collect, transfer, store and process your information outside of your country of residence subject to applicable law. By providing us with your information or using the Site, you consent to the transfer and processing of your information may outside your country of residence.

REVELATION TO THIRD PARTIES

We share Your data with our registered third parties only that includes our regulated monetary partners. It is for the arrangement of services on the Website or App. The way by which we are going to share your data with our third parties are there below:
  • We reveal and distribute Your data with our financial service providers, banks, NBFCs, and third-party partners. It is for the facilitation of the loan process or facility or line of credit or buying a good.
  • We share Your Data with our third-party partners. It is for conducting data analysis and provide you a better service that assists our Platform.
  • We may reveal Your data without giving any notification. We may have to consent from any legal obligation or an order from the public authority or statutory authority. To enforce or apply our terms of use or to assign them with such data throughout corporate divestitures, mergers, or to protect the rights, property, or security of us, our users, or others. It includes exchanging data with other associations and organizations that act as insurance against fraud and credit risk reduction.
  • We will reveal the data provided by any User with the help of other technology partners. With this, we will track how the users interact within the Platform on our behalf.
  • We and our affiliates may share Your Data with other company entities and merge them. We can also acquire the business entity, organization, amalgamation or, restructuring the business for continuity of our business. Now the question is, should such a transaction take place for any business entity (or a new combined entity) and receive such data from us or, shall we go according to this privacy policy depending on your data.
  • We will reveal the data to our third-party technology and credit accomplices for performing credit checks and credit examination like Credit Bureaus or third-party data source providers.
  • We will share Your data under a confidential agreement with our third parties. We also restrict the use of the given data by third parties only for the reasons mentioned here. We guarantee you that there will be no unauthorized divulgence of your information shared with third parties.
  • If you use our Platform, then that means you are accepting your consent to the Company for revealing or disclosing your private data. (i) To the associated third parties in connection with the Services; and (ii) With the public authorities, quasi-governmental authorities, judicial authorities, and quasi-judicial authorities, by the law applicable in India.
  • We may also reveal your journey to KYC or any data concerning the same to the relevant regulatory authorities as a part of our process related to statutory audit measures. Also, note that your Adhar card number will never get revealed to anyone. Even if we reveal your data due to any reason not indicated above, we will take your permission.

CHANGES IN THIS PRIVACY POLICY

We claim the right to change, alter, add or eliminate parts of this Privacy Policy whenever necessary. In this case, if any changes occur in the Privacy Policy, we will update it on the Platform. After posting, those progressions will become effective instantly, unless if anything else is there to express. We urge you to audit this page often to get the latest information on our privacy practices. Proceeded with access or utilization of the Services comprise Your acknowledgment of the progressions and the altered Privacy Policy.

GETTING YOUR INFORMATION / CONTACTING US

Anytime the users can decide to alter, adjust, or withdraw their personal information from being shared on the Platform. Kindly note that erasing or pulling out data may influence the Services we give to you. In case any changes occur in your personal information, users require to furnish the related reports. These reports must identify the changes in your personal information. That will then be used for verification purposes by the Company.

YOUR PRIVACY CONTROLS

You have some options for the data we gather and how to use them:
  • Settings of devices: Your device may have controls that figure out the information we collect. For instance, you can adjust consents on your Android phone for admittance to Camera or Audio authorizations.
  • You may delete the Website or App from your device when needed.
  • You can likewise demand to eliminate the content from servers depending on the appropriate law or by writing to our Grievance Officer.

SECURITY PRECAUTIONS

The Platform protects your information and maintains its accuracy as confirmed by you. We execute reasonable administrative, physical, and specialized guards. It will help us to protect your data from disclosing or using it for unauthorized access or fraud. For instance, we secure all your information at the time of transmitting it on the internet. We also need to know that the enrolled third-party service provider protects such data from disclosing or using it for unauthorized access or fraud.
Our Platform has severe safety measures that protects from any loss, misuse, or alteration of the information and keeps it under control. We attempt to safeguard and guarantee the security of your personal information provided by you. We utilize Secure Sockets Layers (SSL) based on encryption for the transmission of data. At present, this is the necessary degree of encryption in India according to material law.
We combine security at multiple steps within our products. The state-of-the-art technology guarantees our systems to maintain strong security measures. Overall, the data, privacy, and security design allow us to defend our system. These ranges from low hanging issue up to complex attacks. Also, the Website and Website or App have been certified for the following security certifications:
  • ISO 9001: This is the international standard that provides you the detailed requirements for a quality management system (QMS). Organizations that use the norms to describe the capability and consistently provide goods and services to meet customer interests and regulatory requirements with the required security protections.
  • ISO 27001 (also known as ISO/IEC 27001:2005): This is a specification for an information security management system (ISMS). It is the suggested level for certification required under the Information Technology Act, 2000. An ISMS is a framework of policies and procedures that includes all legal, physical, and technical controls. These are involved with data related to organizations hazard the executive's measures.
Our objective is to protect you from unauthorized access, alteration, disclosure, or any destruction of your personal information that we hold, including:
  • We use encryption for keeping your data private on the way to transit.
  • We offer security measures like an OTP verification that will help you to protect your account.
  • We check your information and collect and process practices, including physical security measures, and prevent unauthorized access to our systems.
  • We protect your personal information from getting revealed to our employees and agents who need that information to process it. Anyone with this access is subject to strict contractual confidentiality obligations. They may also be disciplined or terminated if they fail to meet these obligations.
  • Compliance & Cooperation with Regulations and relevant laws.
  • We regularly survey this Privacy Policy and make sure that we process your information in ways that you can agree with it.
  • Transferring of data.
  • We guarantee you that the Aadhaar number will not get disclosed to anybody in any manner.
We or our affiliates try to maintain your information on the servers situated in India. Data protection laws vary among countries, where some provide more protection than others. We also agree with some of the legal structures relating to the exchange of information as mentioned earlier. It is necessary under the Information Technology Act, 2000 and the rules made later.
When we receive any formal written complaints, we react by reaching the person who made the complaint. We work with the appropriate regulatory authorities, including neighborhood information assurance professionals, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.

YOUR CONSENT

If you share your personal information on our Platform, you are giving us the consent to collect, share, divulgence and use your data. You have revealed this data on the platform as per our Privacy Policy. Thus, the information we gather, how we use it, and under what conditions we share them are all known to you.

GRIEVANCE OFFICER

As per Information Technology Act, 2000 and rules made thereunder, the name and contact details of the Grievance Officer are given below for your reference: Success!
  • Name: Mr. Abidi Yusha Yusuf
  • Address: Address:B-11, Shanker Garden, On N.G. Road, Village Possangi Pur, New Delhi
  • Phone Number: +9195998 13916
  • Email address: grievance@cliktoloan.com
  • Time: Mon - Sat (10:00 - 19:00)