and the Information Technology (Reasonable security practices and procedures and
detailed hereinafter below in section II and III, and in accordance with such applicable law.In case you
choose not to share your Personal Data as required, with us, we may not be able to carryoutyour
We may collect following information from you, as you may have disclosed to us:
1. Personal Details such as PAN Card/ Identity Card / Passport details / Aadhaar details / Voter ID /
Driving License/Mobile Number Collection Agent
2. Address Proof of the Collection executive
3. Debt Recovery Agent (“DRA”) Certificates (wherever applicable) of employees that will work on
4. Cancelled Cheque.
5. Bank Statement.
6. Collection Agent’s photograph (applicable in case of field agent)
7. Information obtained from your mobile device by way of using our app like device
location/geolocation,, device information (including storage, model)
Voice recordings of the conversations between the Collection Agency / Agents/representatives and the
Customers as audit, regulatory and quality compliance and statutory requirements.”
8. Voice recordings of our conversations with our customer care agent with you to address your
9. access to your mobile camera device for the functioning of many in- app functionalities including
uploading images or videos that borrower is willing to share that will benefit the collections purposes but
not limited to scan and pay etc. access to device camera is required. Permission is sought for the same at
appropriate stage during the app usage.
10. access to files from your mobile device such as audio, video files for the functioning of many in-
app functionalities including but not limited to in-app chat, access to user’s contacts, files, images, audios
and videos is required. Permission is sought for the same at appropriate stage during the app usage.
11.For the functioning of many in-app functionalities including, but not limited to device binding for user
authentication, access to user’s SMS is required, permission is sought for the same at appropriate stage
during app usage.
II. Sharing and Storage of your Personal Data
Any Personal Data that we have access to shall never be shared without your consent. In various
processes / / availment of product / service offerings, we even seek your explicit consent to use / share
your Personal Data.
In our business and operational processes, we only share the data on a partial and “need-to-know” basis to
designated personnel or partners or service providers.
We may process, store and retain your Personal Data on our servers where the data centers are located,
and/or on the servers of third parties having contractual relationships with us. All Sensitive Personal Data
is stored in India. We will retain your data for the period that you continue to be our Platform/App User
and for such period as required to comply with any obligation under any law for the time being in force.
We will share your data with competent / legal / statutory / regulatory agencies / authorities /auditors or
partners / service providers acting on our behalf (as the case may be) in following cases:
● for enabling the provision of the products / services availed by you, strictly on a “need to know”
basis and subject to applicable laws.
● where it is directed or required by legal / regulatory / statutory / governmental authorities / judiciary
under any applicable laws / regulations or judicial pronouncement though a legally obligated request.
● where it is required by financial institutions to verify, mitigate or prevent fraud or to manage risk or
recover funds in accordance with applicable laws / regulations.
III. Usage of Your Personal Data
We use your Personal Data in our business activities for providing our products/ services and to perform,
among other actions, the following:
1. To facilitate the collections related activities or report on these activities;
2. To undertake research and analytics for offering or improving our products / services and their
security and service quality;
3. To check and process your requirements submitted to us for products / services and / or instructions
or requests received from you in respect of these products / services;
4. To share with you, updates on changes to products / services and their terms and conditions
including platform’s terms and conditions;
5. To take up or investigate any complaints / claims / disputes;
6. To respond to your queries or feedback submitted by you;
7. To verify your identity for us to provide products / services to you;
8. To carry, screenings or due diligence checks as lawfully required by us;
9. To monitor and review products / services from time to time;
10. To undertake financial / regulatory / management reporting, and create and maintain various risk
11. To conduct audits and for record keeping purposes;
12. To comply with the requirements of applicable laws / regulations and / or court orders / regulatory
directives received by us;
13. For the purpose of monitoring and managing all digital, calling & field activities within the
Platform we may keep a track of the following information at a Collection Agency or individual agentlevel:
● Total Calls made
● Total Successful calls made
● Total borrowers contacted
● Contactability ratio/Answer rates
● Total digital communication sent
● Click rates on digital campaigns
● Total Field visits
● SMS campaigns
● Call recordings
● Location tracker & cash pickup tracker for field agents
● Total Payments received
a) Via Digital
b) Via Tele-calling
c) Via field