PLEASE READ THIS POLICY CAREFULLY BEFORE USING THE APP
SmartCoin Financials Private Limited (“us”, “We”, “SmartCoin” or “Company”) are committed to protecting and respecting your privacy.
SCOPE OF POLICY
- SmartCoin mobile application software (“Application” or “App”) available on our site OR hosted on the Google Play Store (“App Site”), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (“Device”).
- Any of the services accessible through the App (“Services”) those are available on the App Site or other sites of ours (“Services Sites”).
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
INFORMATION WE MAY COLLECT FROM YOU
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
We may collect and process the following data about you.
- Information you give us about you (submitted information)
- provided by filling in forms in the App or on the App Site (together Our Sites);
- provided by corresponding with us (for example, by e-mail or chat);
- including information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services (such as applying for a loan), search for an App or Service, share data via an App's social media functions, enter a competition, promotion or survey, and when you report a problem with an App, our Services, or any of our Sites; and
- including your name, address, gender, date of birth, e-mail address, phone number, username, password and other registration information, PAN card, aadhar number, financial information such as employer name, monthly salary, bank account no., bank statements, credit information, login-in credentials of third parties such as social media sites (Facebook, LinkedIn and other such platforms), copies of identification documents, biometric information, digital signature keys, personal description and photographs.
- Information we collect about you and your device. Each time you visit one of our Sites or use one of our Apps we may automatically collect the following information:
- User Personal Information : Our app collects user account data which includes email address and user public profile information like name, photo, ASID depending on the social media platform used by you (such as Google or Facebook) to log in to the app. This information is required as a part of the registration process to access our service and it is also used to auto populate relevant fields in the course of the app interface. Our app also collects mobile number for verification to check the active SIM status on the device, uniquely identify you and prevent frauds and unauthorised access.
- Financial SMS Data : We collect and monitor financial SMS to create a financial summary for your profile, which includes only financial and transactional SMS about bank related transactions, name of transacting parties, description of the transaction, amount of transaction for performing credit risk assessment - all to provide the best loan offers; and to keep the loan process convenient and seamless. We store this financial information on our secure servers. No personal SMS data is ever collected, read or stored by our app.
- Installed Apps Data : We collect and monitor each installed applications metadata information that includes application and package name, installed and updated time, version name and version code for all applications installed on your device. We use this to assess your creditworthiness and provide you with pre-approved customized loan offers.
- Device Data : Our app collects and monitors specific information about your device including your hardware model, RAM, storage; unique device identifiers like IMEI, serial number, SSAID; SIM information that includes network operator, roaming state, MNC and MCC codes, WIFI information that includes MAC address and mobile network information to uniquely identify devices and to prevent fraud. This also helps in enriching your credit profile and providing you with the best loan offers according to your profile.
- Phone Book Contacts : Our app requires this permission to detect loan application references and provide a better user experience for certain features in the app like app invitations. We also collect and monitor your phonebook contacts information, that includes name, phone number, account type, modifications to contact, favorites and other optional data to enrich your financial profile and provide a better understanding of your creditworthiness. This helps us in detecting fraud loan applications and reducing credit risk.
- Location Data : We collect and monitor the information about the location of your device to service your loan application, to reduce risk associated with your loan application and to provide better loan offers. This also helps us to verify your addresses and make a better credit risk decision.
- Storage : We require storage permission so that your kyc and other relevant documents can be securely downloaded and saved on your phone. You can then easily upload the right KYC related documents for faster loan application details filling and disbursal process. This ensures that you are provided with a seamless experience while using the application.
- Usage Data : details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data, location data, weblogs and other communication data (Log Information).
- Information we receive from other sources (“Third Party Information”). We may collect information about you from a limited number of third parties such as credit bureaus and other identity verification and fraud prevention services. You may choose to provide us access to certain third parties like credit information companies, the UIDAI servers for e-KYC and e-Sign services, social media sites, banks and financial institutions with whom you maintain a banking relationship. This information we collect from such third party sources is governed by your privacy policies agreed with those sources and with your express consent.
- Unique application numbers. When you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
TRACKING & COOKIES
We may use mobile tracking technologies and/or website cookies to distinguish you from other users of the App, App Site, Appstore or Service Site. This helps us to provide you with a good experience when you use the App or browse any of the sites and also allows us to improve the App and our sites.
USES MADE OF THE COLLECTED INFORMATION
We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
Information collected by us shall be used to :
- perform background verification including satisfying the KYC due diligence as mandated by the Reserve Bank of India and to perform credit checks on the customer;
- determine whether or not to provide a loan to the customer, the amount of such loan and the terms and conditions applicable to such loan;
- provide effective Services to the customer and assist in the event he/she needs additional support; and
- comply with our legal or statutory obligations.
We do not disclose information about identifiable individuals to other parties, but we may provide them with anonymous aggregate information about our users (for example, we may inform them that 500 men aged under 30 have applied for a loan on any given day).
DISCLOSURE OF YOUR INFORMATION
We may disclose some or all of the data we collect from you when you download or use the App to credit reference bureaus.
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
We may disclose your personal information :
- with employees, affiliates, vendors, partners and third parties as may be required to offer the Company’s Services;
- if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request;
- with other corporate entities and affiliates to help detect identity theft, fraud and other potentially illegal acts, verify your KYC details, retrieve your credit information / bank account details to prevent abuse of our Services, provide customer service and support and resolve disputes;
- in the event that we sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets;
- if SmartCoin or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; and/or
- in order to: enforce our Terms and Conditions and other agreements or to investigate potential breaches; report defaulters to any credit bureau; or for the purpose of publishing statistics relating to the use of the App, in which case all information will be aggregated and made anonymous.
Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Our Sites; any transmission is at your own risk. By using this App, you agree that the Company will have no liability for disclosure of your information due to errors in transmission, infrastructure failures by the Company or any intermediary (including telecom and internet service providers), or unauthorized acts of third parties.
We will use your data for the purposes of compiling statistics relating to our user base or loan portfolio and may disclose such information to any third party for such purposes, provided that such information will always be anonymous.
Should we wish to use your information for marketing purposes, we will inform you prior to such use. You shall be entitled to prevent such usage by informing us, within 10 days of being informed of the proposed use, that you do not wish to disclose such information. You can also exercise the right at any time by contacting us at firstname.lastname@example.org.