For the purpose of this policy:
b) Whenever the context so requires, “you”, “your”, “user”, and “Customer” shall mean any natural or legal person who browses through the Platform or avail services through the website, and the terms “we”, “us”, and “our” shall mean the Company.
Saarathi is committed to ensuring that Your privacy is protected. This policy is provided to explain Our policies and practices regarding the collection, use, and disclosure of information about You. When you use Saarathi, certain information and data such as your IP(Internet Protocol) addresses, the duration and time of your use of our Platform, services, programs, and systems used on Saarathi, or certain other information or data provided voluntarily by you on Saarathi are retained by us on our server. We understand that the privacy of your information is important to you. We value and respect your privacy and are committed to following and maintaining the highest standards of industry practices.
We, therefore, advise you to read this policy before using our Platform. If these terms, in parts or whole, are not acceptable to you, then you are advised not to use Saarathi or our services that require the collection, use, or retention of your information.
3.1. “Cookies” means small text file created by Saarathi that is stored on your device, either temporarily (session cookies) or permanently (persistent cookies), that remembers the information about you to recognize your device and set your preferences as per your usage of Saarathi.
3.2. “Channel Partner” (CP) or “Direct Selling Agent” (DSA) shall mean the person who acts as an agent who uses the Platform to provide services to the Customer.
3.3. “Customer” shall mean the person whose personal information is being shared with us by the Channel Partners.
3.4. “Information” means your data that is collected by us during your usage of Saarathi and includes Personal, Non-personal, and financial information.
3.5. “Personal Information” means personally identifiable information that can be used to contact or identify you or the Customer. Personal information includes, without limitation, the name, email address, residential and permanent address, date of birth, phone number, Aadhar card, pan card, and other financial information, including, without limitation, income, expenses, credit history, credit score, payment details, bank accounts information and other information as required from time to time.
3.6. “Non-personal Information” means information such as cookies, log data, third-party analytics for data collection, and analysis that your browser sends whenever you use Saarathi, and includes, without limitation, information such as your computer’s Internet Protocol address, browser type, browser version, pages of Saarathi that you visit, time and date of your visit, time spent on those pages, unique device identifiers, the mobile device you use(including the hardware models), your mobile device unique ID, IP address of your mobile device, your mobile operating system, type of mobile Internet browser you use, unique device identifiers, location, device data, and other diagnostic data.
3.7. “User” shall mean the Customer who provides information on the Platform as well as the Channel Partner who provide the Customer’s Information on the Platform.
4. COLLECTIONOF INFORMATION
4.1. Non-personal Information:
We collect your Non-personal Information, such as the device ID, device model, IP address, browser type, operating system, and the time and frequency of use of Saarathi when you browse through Saarathi or use Saarathi to avail of the services.
4.2. Personal Information:
We collect your Personal Information only whenyou voluntarily provide it to uswhile:
a) Browsing Saarathi
b) Creating an account on Saarathi
c) Availing Services available on Saarathi
d) Inquiring about our services
e) Providing feedback
f) Using live chat support
g) Availing service support
h) Providing information on our Platform
a) When You add Your pin code on the application
b) From Your mobile device when enabled by You to do so. We collect this data only when our application is being used. You may have restricted access to the Application/services available through the Application if You disable/ withdraw/do not provide this access
a) We do not collect any Personal Information of any individual except when a such individual voluntarily shares Personal Information on our Platform directly or through the Channel Partner with prior written consent. Upon such voluntary disclosure of Personal Information and data, we may further verify and collate the information and data from information available in the public domain (as permitted by law) to prevent identity theft, fraud, etc.
b) As per Government regulations, we do not collect personal information from anyone who is a minor or has not attained the age of 18(Eighteen). Any such information, if collected, could be removed from our servers if the parent or guardian becomes aware of such personal information being revealed to Saarathi. Such Guardians or Parents can contact us via our help care number or email. Such information will be removed from our servers at the earliest. We do not knowingly collect Personal Information from anyone under the age of 18 years. If we become aware that we have collected Personal Information from children without verification of parental consent, we take immediate steps to remove that information from our servers. Therefore, if you are a parent or guardian who becomes aware that a minor has provided us with Personal Information, please contact us for removal of the same from our servers.
5. RETENTIONOF DATA
You can choose to edit, change or delete your Personal Information, in parts or whole, that you have provided on Saarathi. We will retain your Personal Information as long as you continue to remain a user of Saarathi by using services available on Saarathi or until it is required for us to retain your Personal Information to resolve disputes, if any, or to enforce our legal agreements and policies. If you want us to delete your information, write to us at firstname.lastname@example.org
6. DISCLOSUREOF DATA
6.1. We will not voluntarily disclose your stored information without your prior written consent. We may disclose your information to our domestic or international affiliates, subsidiaries, joint venture partners, licensees, and representatives, solely for the purposes stipulated in this policy.
6.2. Permitted Disclosure: Notwithstanding anything provided in the foregoing clause, we will disclose your information in parts or whole under the following conditions:
b) Third-Party Service Provider(Financial Institutions): For providing Services available on Saarathi which is rendered to you through the help of third-party service providers (Financial Institutions) such as Banks, Non-Banking Financial Company (NBFC), Insurers, Brokers, Mutual Funds, AMCs, etc. we may be required to share your information, in part or whole, to third-party service providers; thereby we will share your information with such third-party service provider as required for rendering such Services to you. Such disclosure, however, shall be made under strict confidentiality obligations, which inter alia restricts disclosure of your information to any person or entity by a such third party, its employees, associates, and affiliates.
d) Legal Requirements: We will disclose your information in good faith and belief if such action is necessary to comply with a legal obligation or to protect and defend the rights and property and restrict the legal liability of the Company, or to prevent or investigate possible wrongdoing in connection with the Platform or to protect the personal safety of the users of Saarathi.
e) We shall not be held liable for disclosure of the Customer Information or Statistical Information in accordance with this Privacy Commitment or in terms of any other agreements with you.
f) We may disclose Customer Information to any of our associates and affiliates without any limitation, and you hereby give your consent for the same.
g) We may disclose the Customer Information, to third parties, without limitation, for the following reasons, and you hereby give your irrevocable consent for the same:
a. To enforce the Terms and Conditions of the products or services. or
b. To protect or defend our rights, interests and property or that of our associates and affiliates, or that of our or our Affiliate’s employees, consultants etc. or
c. For fraud prevention purposes. or
d. As permitted or required by law.
h) We may disclose the Customer Information to third parties for the following, among other purposes, and will make reasonable efforts to bind them to the obligation to keep the same secure and confidential and an obligation to use the information for the purpose for which the same is disclosed, and you hereby give your irrevocable consent for the same:
i) For sharing with third-parties information obtained once (such information will only be taken one time, the information obtained once will only be shared) with your consent from your mobile device like device location, device information (including storage, model, installed apps, Wi-Fi, mobile network), transactional and promotional SMS, communication information including contacts and call logs, for statistical modelling, credit scoring and any other purpose that will help us in providing you with optimal and high-quality services.
7. USE OF INFORMATION
7.1. By the Company:
a) We will use your information to provide Services available on Saarathi to you; to notify you about changes in our Services or terms and conditions for such Services, or deliver any administrative notices, alerts, advice, notifications, and communication relevant to Your use of any of the facilities on the application through social media, Instant messaging, SMS and other mediums; to allow you to participate in interactive features of Saarathi when you choose to do so; to provide service support, gather valuable information or analysis to improve our Platform and Services provided thereof.
b) We will use your information and analyze your usage of the application to improve and develop our Platform and Services provided thereof by gathering and analyzing surveys taken, feedback, reviews, and ratings provided or posted by you.
c) To fulfil KYC (Know Your Customer) compliances under anti-money laundering laws applicable from time to time.
d) To provide service support and promptly and satisfactorily respond to and resolve your queries, complaints, and grievances, if any.
e) Facilitate credit assessment and personalized offers
f) Undertake market research, project planning, and problem troubleshooting and to protect against error, fraud or other criminal activity
g) Disclose to employees, agents and representatives on a need-to-know basis as part of the services
h) Disclose to relevant and authorized financial service providers and Financing partners who have partnered with Saarathi to provide loan facilities to the customers.
i) Assist in resolving disputes in relation to loan facilities made available by Financing Partners
j) Disclose to the credit information bureau and such other authorities as may be required by applicable laws and
k) Such other purposes as provided in this policy
Saarathi may also be required to share Personal Information with its third-party contractors, such as financial service providers, banks, or NBFCs/Financing Partners. In such cases, Saarathi shares the information securely and ensures that all personal information recipients comply with confidentiality, fidelity and secrecy obligations and sign covenants in this regard. Such third parties will provide the same or equal protection to the user data as provided in this policy. Saarathi may make information available to third parties that are financial and non-financial companies, such as service providers, government agencies, courts, legal investigators, and other non-affiliated third parties, as requested by You or Your authorized representative, or otherwise when required or permitted by law.
In addition to registration, Personal Information may be asked for reporting a problem/complaint with Saarathi. We may send You emails about Our Application, new products, payment reminders, and other updates. We may use the phone number provided and verified by You to reach out to You via call, WhatsApp, and SMS. Saarathi will ensure that the Personal Information provided by You is treated securely, in accordance with the provisions of this Policy and the Rules. You are advised to refrain from posting personal information anywhere on the application other than those specifically required by Saarathi. The account information and profile are password protected. Saarathi will never ask for Your password through unsolicited phone calls or emails. However, if any person claiming to be an authorized representative of Saarathi contacts You, We request You not to provide any information to such person and instead immediately contact Saarathi as per the contact details provided in this policy. Saarathi shall not be liable for any loss of Personal Information provided to such persons.
7.2. By Third-Party Service Provider:
b) Credit Information Company: Your financial information may be subject to disclosure to third-party service providers for the preparation of your credit report when such services are availed by you through Saarathi. Such information is disclosed to such third-party under confidentiality obligations.
c) Other third-party service providers and facilitators: Your information will be used by other third parties, such as banks, NBFCs, etc., when you use Saarathi for availing a financial product, making payments, money transfers, or any other financial transaction of any nature as available on Saarathi.
8. THIRD-PARTY LINKS AND CONTENTS THEREOF
Our Platform may link to third-party websites and services that are outside our control. Such third-party websites may collect and store information and data about the user. The Company takes no responsibility for the privacy practices followed by these websites or the content available thereon. The Company takes no liability for any loss or damage arising directly or indirectly from using such websites by browsing or transacting through them.
9. SECURITYOF DATA
9.1. We have implemented and employed existing and necessary internet security methods and technologies to secure the information and data, to prevent loss and misuse of the information, and to data disclosed through unauthorized access from third-party, alteration, disclosure, or destruction of your information, username, password, transaction information and other stored Information on Saarathi.
9.2. The Platform is scanned regularly for any vulnerabilities to make your usage of Saarathi as safe as possible.
9.3. We assure the compliance and adoption of all such measures as required under the applicable laws from time to time.
9.4. The protection and confidentiality of your username, password, and other login credentials is solely your responsibility, and we recommend you not to disclose it to anyone, including any third party, including anyone claiming to be there presentative of the Company or its affiliates. We never call or ask for such information from users. We shall not bear any responsibility or liability for such unauthorized disclosure or usage of your information or action taken from your account and its consequences thereof.
9.5. Notwithstanding anything provided under this policy, the Company shall be under no obligation for the permitted disclosure of information per the terms of this policy.
9.6. Although we use our best endeavors to protect and secure the information and data shared or transmitted over the internet cannot be completely guaranteed; hence we cannot provide an absolute hundred percent guaranteed security of the information provided by the user. Therefore, we disclaim all warranties and liabilities in respect of:
a) Any loss or injury caused to you as a result of voluntary disclosure of your Personal Information to any unauthorized party.
b) Privacy practices and security of your information collected by third-party websites and services provided thereof that are outside our control.
11. GRIEVANCE REDRESSAL
*Note: We have attached an appendix wherein details of NBFC and Banks are mentioned for reference, wherein Customers, as well as other entities, can look up our partners or banks as per recent regulatory norms.
Grievance Redressal Officer
12th Floor, Tower – B,
M3M Urbana Business Park,
Behind M3M Urbana, Sector 67, Gurugram,