PRIVACY POLICY
Last Updated: 4th August, 2022 at 5 PM IST.
MobCast Innovations Private Limited, having its registered office in Mumbai, Maharashtra, and its affiliates (hereinafter referred to as “MobCast”, “we” or “us”), is committed to protecting and respecting your privacy. We collect, use, disclose, transfer, process, share and store your personal information when you are using our services on [https://getmunshi.in] (“Platform”). Please read carefully and familiarize yourself with our privacy practices before using our services or providing your Personal Information.
HOW WE COLLECT AND USE YOUR INFORMATION
We collect your Personal Information along with other information for efficient operations and to provide you with a good user experience. Our channels for collecting Personal Information and other information includes (a) information directly provided by you to us; (b) information collected by us during your use of our Platform; and (c) information collected about you from third parties, to the extent permitted under applicable law.
The information we collect depends on the service and product you are using, the environment in which you interact with us, the choices you make and the products and features you view and use. If you choose not to permit us to collect such information we may not be able to provide you with relevant products and respond to your queries or resolve any problems which you encounter.
“Personal Information” means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person.
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HOW WE COLLECT YOUR PERSONAL INFORMATION
1. Information Directly Provided By You to Us
Some Services we offer require that you submit information to us directly. For example:
(a) When you create an account or profile with us, we may need to collect your Personal Information such as your mobile phone number or email address. When you register with us by logging in through your third party account like Google, Facebook etc. (Third Party Account) or link your profile with your Third Party Account, you may need to share/upload certain Personal Information such as your name, gender, date of birth, e-mail address, mobile number and profile picture.
(b) In order to apply and/ or to avail any of the Services, you may need to provide us or upload your Personal Information, such as your name, birthday, marital status, residential details, mobile phone number, email address, contact address, proof of income, financial information such as bank documents, salary slips, bank statements, PAN card and/ or other government issued identifications, bank name and bank account number, data and documents required for Know Your Customer compliances as per the applicable law and other relevant details (including Personal Information), details regarding your employment, and any other information you provide us. In this respect you irrevocably undertake to provide us solely your information and documents which are true and correct to your knowledge. You shall not provide us with any misleading or incorrect information.
(c) When you use chat function on the Platform to contact our customer service, we may collect your Personal Information such as your account ID and chatting history.
2. Service Usage Information
We may also collect information about your use of our Services through software on your device and other means, including:
(a) Device Information - Such as device name, device model, device identification code, device hardware information and status, use habits, IP address, Mac address, operating system version, serial number and the configuration of the device used to access the Services;
(b) Log Information - Such as when and how long the Platform is used, search terms entered through the Platform and information about device and software events;
(c) Location information - Such as the GPS signal of the device or information related to the nearby Wi-Fi access points and cell towers;
(d) Camera and gallery information about Image properties - Such as, inter alia, to provide you with the function to choose photos from gallery and/or authenticate image property;
Session data - We automatically log generic information about your device’s connection to the Internet, which we call “session data”. It may be anonymous and may not be linked to your Personal Information. Session data consists of information such as the IP address, operating system, type of browser software you used and your activities on our Platform. We collect session data to ascertain how our visitors use our Platform, including information relating to the frequency of visits, average length of visits, pages viewed during a visit and other summary data that we gather as usage statistics. It also helps us diagnose problems with our Servers and lets us better administer our systems.
3. Information Obtained from Third Parties
Based on the characteristics and requirement of the Services and to the extent permitted by law, we may obtain your Personal Information from public or commercial sources and Third Parties such as the third party agencies engaged by us for and/ or in connection with the provision of Services, and may combine that information with other information received or collected by us which is related to you. For example, if you choose to link your profile or log in and use our Services via your Third Party Account, we may obtain your information from such account.
You comprehensively and unequivocally authorize us to use your Personal Information obtained from Third Parties.
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HOW WE USE YOUR INFORMATION
We will process your Personal Information, for the purposes stated in this Privacy Policy or in connection with our obligations to you under the Terms of Service, other legally binding obligations, or when we believe that such processing is required to protect the legitimate interests of ours or Third Parties after evaluation. We will use your Personal Information in strict accordance with this Privacy Policy and its updated content.
We will use your Personal Information for the following purposes:
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To register and maintain the account to use the Services;To comply with the law and legal procedures.
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To provide the Services to you;
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To verify your identity and to prevent, discover and investigate any frauds, security issues and any other illegal activities or behaviors violating the contracts with us in order to protect the legitimate interests of the relevant parties;
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To provide customer support, such as communicating with you about the Services or addressing any general queries;
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To provide notification and push services;
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To improve/augment products and user experience;
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To provide you with personalized service;
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To carry out commercial promotion activities, such as providing marketing and promotional materials. You have the right to opt out of our proposed use of your Personal Information for direct marketing. If you no longer wish to receive certain types of email communications you may opt-out by following the unsubscribe link located at the bottom of each email. We will not transfer your Personal Information to our Partners for direct marketing;
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To analyze statistical information about the use of the Platform to improve our services;
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HOW WE USE COOKIES
For your understanding, we have explained below what Cookies are:
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What Are Cookies?
Cookies and other similar technologies, such as pixel tags and web beacons may be used by us and our Partners. Cookies may be stored on your device for a short period of time (e.g., only when your browser is open) or for a long period of time, even years. We cannot access the Cookies that are not set up by us.
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How To Manage Cookies
Cookies and Cookie Preferences shall only be managed from the Options/Preferences panel of your browser.
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Know More About Cookies
For more information about cookies and instructions on how to configure your browser to accept, delete or disable cookies, see www.aboutcookies.org.
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HOW WE RETAIN YOUR PERSONAL INFORMATION
The retention period of the Personal Information we collect is the minimum amount of time required to achieve the purposes of collection stated in this Privacy Policy, unless a longer retention period is required by law. We will delete or anonymize your Personal Information upon expiry of the retention period as described above.
Notwithstanding anything mentioned herein or in the Terms & Conditions, you understand and acknowledge that we and our Partners (including their respective business partners who are involved in order to directly or indirectly provide the Services to you) reserve the right to retain your information including Personal Information and to track your mobile location during you availing or we providing the Services (actively or passively). This right continues, without restriction, till the closure of all loans, payment by you of any outstanding amounts owed, and/ or maturity/ closure of all services or products which you may have taken or subscribed using the Platform. Such right remains unaffected by the deletion of the Platform, or long period of inactivity on the Platform.
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HOW WE DISCLOSE YOUR PERSONAL INFORMATION
We do not sell, rent, lease your Personal Information to any third parties and will never do so. We share Personal Information only as described herein.
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Affiliated Companies: we may share certain Personal Information with our affiliated companies. We only share necessary Personal Information subject to the purposes stated in this Privacy Policy. If the affiliated companies wish to change the purposes of processing, they will ask for your consent again.
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Third Parties: we may use or appoint certain third-party companies and individuals to help us provide, analyse, and improve the Services or Perform functions on our behalf. Such Third Parties include but are not limited to data storage facilities, SMS or other technical service providers, payment or financial service related service providers. Such Third Parties have access to your Personal Information to perform their respective functions or purposes as set out herein above, but may not use it for other purposes. Further, they are required to process the Personal Information in accordance with this Privacy Policy and as permitted by applicable laws.
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Partners: to realise the purposes stated in this Privacy Policy, some of the Services will be provided by our Partners. We will share some Personal Information with our Partners, including but not limited to Lenders, and credit information companies to provide Services to you. For the purpose of retrieving your credit score, such credit information companies may further share your information with the relevant credit bureaus. We contractually bind our Partners to prevent them from using/disclosing your Personal Information, except for the purpose of providing the Services opted by you. However, we cannot be held responsible for the actions of the Partners. These Partners control and manage your Personal Information. Before using the services and products of our Partners, please carefully read the respective Partner’s terms and conditions and privacy policy which you can view on their websites and/ or which may be mentioned in the agreements you may execute with them.
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Persons Who Acquire Our Assets or Business: If we sell or transfer, wholly or in part, any of our businesses or assets, your Personal Information may be a part of that sale or transfer but it will remain subject to the promises made in this Privacy Policy (unless, of course, you consent otherwise).
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Legal and Regulatory Authorities: We may be required to disclose your Personal Information due to legal or regulatory requirements. In such instances, we reserve the right to disclose your Personal Information as required in order to comply with our legal obligations, including but not limited to complying with court orders, warrants, or discovery requests. We may also disclose your Personal Information (a) to law enforcement officers or others; (b) to comply with a judicial proceeding, court order, or legal process served on us or the Platform; (c) to enforce or apply this Privacy Policy or our Terms of Service or our other policies or agreements; (e) for an insolvency proceeding involving all or part of the business or asset to which the information pertains; (f) respond to claims that any Personal Information violates the rights of third parties; (g) or protect our rights, property, or personal safety, or the general public. You agree and acknowledge that we may not inform you prior to or after disclosures made according to this section.
Notwithstanding anything mentioned hereinabove, we shall not be responsible for the actions or omissions of any Third Parties with whom your Personal Information is shared by you nor shall we be responsible and/ or liable for any additional information you may choose to provide directly or indirectly to any of the Third Parties while applying or availing their services and products whether directly or indirectly or whether through the Platform or otherwise.
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HOW WE PROTECT YOUR PERSONAL INFORMATION
We have taken reasonable and feasible technical security and organizational measures to protect the information collected for the Services. However, please note that while we have taken reasonable steps to protect your information, no website, Internet transmission, computer system, or wireless connection is absolutely secure.
We strive to adopt security measures that are in line with industry standards to protect your Personal Information you provide and to prevent unauthorized access, public disclosure, use, modification, damage or loss of the data. We will take all reasonable and practical steps to protect your Personal Information, including:
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We will use technical means to encrypt many of our Services. We will on regular intervals examine our practice of information collection, storage, and processing to prevent unauthorized system access. For such purposes, we follow the International Standard IS/ISO/IEC/ 27001 (Information Technology - Security Techniques - Information Security Management System - Requirements) standards and procedures;
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We will strictly control the access to Personal Information, and only allow our employees who need to know the Personal Information to help us process such information, and personnel of companies authorized to handle the Services on our behalf to access such Personal Information. These employees and personnel are required to fulfil strict contractual confidentiality obligations. Should they fail to fulfil these obligations, they may be held accountable for legal liabilities or their relationship with us may be terminated. Access logs of Personal Information will be kept and periodically audited.
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The security of your Personal Information is of great importance to us. Therefore, we will continue our efforts to protect your Personal Information and implement safeguard measures, such as providing encryption for information storage and transmission in an effort to prevent your Personal Information from unauthorized access, usage or disclosure;
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We will endeavour to prudently select Partners and third-party service providers and also endeavour to implement the requirements for Personal Information protection to the business contracts or audits and assessments between both parties;
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We will conduct security and privacy protection training courses, testing and publicity activities, and annual audits to enhance employees' awareness of the importance of protecting Personal Information.
In the event of a Personal Information security incident, we, if and how required and in accordance with the requirements of relevant laws and regulations promptly inform you of the same and the preventive measures to be undertaken to mitigate the damage.
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YOUR RIGHTS TO YOUR PERSONAL INFORMATION
Below is a list of your, non-exhaustive, legal rights as well as the measures that we take to protect these rights.
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Right to be Informed: We publish this Privacy Policy to inform you of what we collect and how we process your Personal Information. We are committed to being open and transparent about how we use your Personal Information.
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Right to Access: You may request access to the Personal Information that we process about you, which includes the right to obtain information on and a copy of such Personal Information.
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Right to Correct: If you find that the Personal Information we processed about you is inaccurate or incomplete you may, on most occasions, have the right to have us rectifying or amending it unless we or any of our Partners have acted upon or made to have acted upon such incorrect or incomplete information provided by you. For parts of your Personal Information, you can directly correct and modify it on the relevant function page of the App. For Personal Information that has not been made available for your modification, you can request correction or supplementation by contacting our grievance officer at (Mr. Raghav) [raghav@mobcast.in]. You undertake to keep your Personal Information updated, at all times, to help us serve you better.
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Right to Delete: When you find us collecting or using your Personal Information in violation of relevant laws, administrative regulations or this Privacy Policy you have the right to ask for deletion of relevant Personal Information and in such situations you may ask us to delete the Personal Information submitted by you or make them anonymous by contacting our grievance officer (from your registered sources of communication such as registered mobile or email) and our grievance officer will look into the same and revert or act upon the same accordingly. Provided that, in case we and/or our Partners are required to delete any part of your information including Personal Information, then we and/ or any of our Partners, as the case may be, may no longer be able to provide you with the Services, in whole or in part, and may accelerate your loan or ask you to pay all outstanding amounts and charges immediately on demand and/ or pursue all legal remedies available in case you fail to adhere to the said demands within the stipulated timelines. Please also note that, there may be circumstances where you ask us to delete your Personal Information, but we are legally entitled to retain it.
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Right to Withdraw Consent: Each Service available on the Platform requires some basic information including your Personal Information, consents and Platform authorizations. You can grant or withdraw your authorisations and consents at any time, unless you have already availed Services which prohibit the withdrawal of authorisations and consents, such as loans etc. Unless otherwise agreed by us, the prerequisite for withdrawal of consent and authorization or request for deletion of any of your Personal Information requires closure of all pending loans and/ or complete settlement of all payments or charges pending from you to us or any of our Partners. Please also note that, if you withdraw your authorization or consent we may no longer be able to provide you with the corresponding Services.
If you withdraw your consent we will no longer process your corresponding Personal Information or other information. But your decision to withdraw your consent will not affect the processing of Personal Information and/ or other information based on your previous consent prior to the withdrawal. You may change the scope of your consent within which we are authorized by you to continue to collect your Personal Information and/ or other information or withdraw your authorization by disabling corresponding device permissions.
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Right to Complain: You have the right to file complaints in respect of privacy concerns by contacting our Grievance Officer (Mr. Raghav) at [raghav@mobcast.in]. Pursuant to receiving complete information and details of your complaint, we will respond within 30 days from the date of receipt of your complaint and try and resolve your complaint.
Please note that due to security reasons we may verify your identity before processing your request pursuant to any of your rights as described above. In principle, we do not charge any fees if your request is reasonable. However, based on the actual situation we may impose a certain fee to cover our costs for repeated requests or requests that extend beyond reasonable limits. We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), may be detrimental to the legal rights and interests of others or are very impractical. In addition, we may not be able to respond to your request if your request is directly related to matters involving national security, national defence, public health, criminal investigation and other public interests, or if the request may severely impair the legitimate rights and interests of yours or those of other individuals and organizations.
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HOW THIS PRIVACY POLICY IS UPDATED
We may update this Privacy Policy from time to time and you are encouraged to check this Privacy Policy on a regular basis to be aware of the changes made to it. Keeping the Platform installed on your device(s), access or use of the Platform, continued use of the Services (whether actively or passively) shall be deemed to be your acceptance of this Privacy Policy.