Privacy Policy

Synergenius Growth Private Limited (“we”, “us”, Company,” or “our”) including our online website(s) www.finfinity.co.in.in (“Website”) and our mobile applications on iOS and android platform (“Applications”) (collectively referred to as the “Platform”) is committed to protect your privacy. This privacy policy (“Policy”) seeks to comply with the provisions of the Information Technology Act, 2000 (“Act”) and the Information Technology (Reasonable security practices, procedures and sensitive personal data or information) Rules, 2011 ("Rules") that require publishing of the Policy for collection, use, storage, sharing, processing and transfer of Personal Data (as defined below). This Policy has been prepared to describe to you our practices regarding the Personal Data, we collect, use, store, manage, share, process, and/or transfer through our Website and/or Applications and/or others channels (if applicable), in connection with our services, as described in our Terms of Service available at www.finfinity.co.in.in (collectively, the “Services”). This Policy describes the types of Personal Data the Company collects, why and how the Company uses Personal Data, with whom the Company shares it, and the choices you can make about the Company’s use of Personal Data. This Policy also describes the measures the Company takes to protect the security of the Personal Data and how you can contact the Company about its privacy practices. By accessing or using the Website, Services, Applications, or any of our offerings, or giving us your Personal Data, or otherwise clicking to accept this Policy, if and when prompted on any of the Platforms, you confirm that you understand and consent to this Policy, together with any documents that may be expressly referred to and are incorporated by reference, and you undertake that you have the capacity to enter into a legally binding contract through this Policy, which constitutes a legally binding document between you and the Company under the Applicable Law. The Company will collect and process your personal and third-party data carefully, only for the purposes described in this Policy and only to the extent necessary as defined herein and within the scope of the Applicable Law. By accepting this Policy, you understand and agree to the collection, use, sharing, transfer, handling and processing of Personal Data as specified in this Policy. If you are providing the Personal Data on behalf of someone else, you confirm that (a) such information is true, accurate and up-to-date; (b) such third person is aware that you have provided their Personal Data; and (c) they consent to both, the disclosure and the use/ processing of their Personal Data in accordance with this Policy. If you accept this Policy on behalf of another person, you represent and warrant that you have full authority to bind such a person to these terms. Please read the terms and conditions of this Policy carefully, before accessing or using any of our Platforms. You will be deemed to be a “User” who is legally bound by this Policy.

• Account means a unique account created for you to access our Service or parts of our Services using any of our Platforms;
• Applicable Law means the law in force, as amended from time to time, relating to the collection, storage, processing, and transfer of Personal Data, and includes the Rules and any subsequent rules enacted by any Governmental Authority;
• Business Data means any information or data that may be used by us to identify a business, which includes name, address and email of the entity, incorporation date, brand name (if any), contact details, company identification number (CIN), names of the directors, GST Number, financial information such as bank account details, PAN and such other information as available on the respective portals maintained by GST authorities, income-tax department, and the Ministry of Corporate Affairs;
• Company shall have the meaning as ascribed to the term in the preamble to this Policy;
• Consent means the consent obtained by the Company from a User in writing, through letter or fax or email or through any other digital means, prior to the collection of Personal Data regarding the purpose of and usage of such Personal Data;
• Country refers to India;
• Device means any device that can access the Services such as a computer, a cellphone, or a digital tablet;
• Governmental Authority means any national, state, local or regional government or governmental agency, department, board, commission, regulatory authority, semi-governmental authority or arbitrator, court, tribunal, judicial or quasi-judicial authority (including, any stock exchange or any self-regulatory organization established under any law);
• Non-Personal Data shall have the meaning ascribed to the term in paragraph 3 below.
• Personal Data shall collectively mean Personal Information, SPDI, Business Data, Non-Personal Data and Usage Data.
• 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. For the purpose of this Policy, Personal Information includes (a) name, e-mail address, phone number, display picture, username, password, residential address, gender, and other demographic information provided by a customer while availing any product from the lending/ non lending partners of the Company or any other kind of SPDI; (b) information provided to the Company through interaction with the customer service representative, participation in surveys or marketing promotions, or provided to the Company or its representative over the phone or by way of email or other communication channel; (c) providing one time access to customer’s camera, microphone, location, and mobile device strictly for the purpose of onboarding or completion of know your customer (KYC) requirements of the Company’s lending partners for availing products from any of the Platforms, subject to explicit consent of such customer, and in accordance with the digital lending guidelines issued by the Reserved Bank of India, as amended from time to time. The Company limits the collection of Personal Information to that which is necessary for its intended purpose.
• Policy shall have the meaning as ascribed to the term in the preamble to this Policy;
• Rules shall have the meaning as ascribed to the term in the preamble to this Policy;
• Service shall have the meaning as ascribed to the term in the preamble to this Policy;
• SPDI shall have the meaning as ascribed to the term in the Rules;
• Usage Data refers to data collected automatically, either generated by use of the Service, Platforms, or from the Service infrastructure itself (or through the third party analytics service providers), and includes the data in the nature of system administrative data, statistical and demographical data, and operational information and data generated by or characterizing use of the Platforms including without limitation Non-Personal Data, cookies, Website/ Applications traffic, time spent on the Platforms, number of visits to the Platforms and other similar information and behaviour indicating the mode and manner of use of the Platforms.
• Website shall have the meaning as ascribed to the term in the preamble to this Policy; and
• you or Your means the individual or entity accessing or using the Services, Platforms and/or providing Personal Data to the Company.

The Company collects and processes the Personal Data strictly for the purposes described in this Policy. For clarity, the Company collects the following types of Personal Data:

Sr. No	Purpose and specific use cases	Type of data collected for the specified use cases
1	Personal Data collected at the time of visiting/ using the Website and/or Applications	No data collected while surfing the website, whereas while using the website, Full Name, Email ID, Phone Number, PAN is required.
2	Personal Data collected at the time of account creation on the Website, and/or Applications	Full Name, Email ID, Phone Number, PAN, Aadhar, Banking details is required.
3	Personal Data collected if the customer proceeds with availing any lending services on any of the Platforms	For availing any lending service Full Name, Email ID, Phone Number, PAN, Aadhar, Salary Slip for 6 Months, ITR for past 3 Years, Bank Statements, Credit Report, All details fetched from GST portal, Udyam Registration Number, all financial fetched from MCA portal. Other KYC details as required by lenders. Details of Property/Vehicle/other collateral. Selfie/ Photo
4	Personal Data collected if the customer proceeds with availing any non-lending services on any of the Platforms	Full Name, Email ID, Phone Number, PAN is required. Financial Details such as Bank Name, Account Number, IFSC code and current Address required.
5	Personal Data collected through your interactions with any of the employees or other individuals of the Company during availing our Services or offerings	Not Applicable
6	Promotion and marketing communications to send You newsletters, promotional content, confirmations, etc.	Mobile No, Email ID, Full name, Official Email ID, Office name
7	Automatically collected Data Usage Data collected when You interact with us on a digital medium;	Usage Data, including pages visited, features used, and duration Device ID, IP Address, OS version
8	Compliance with legal obligations to comply with disclosure obligations in accordance with Applicable Law; to respond to summons, subpoenas, search warrants, court orders, or other legal process.	Any Personal Data collected by Us

For devices with biometric authentication, the Applications offer the convenience of unlocking using face identification or fingerprint recognition. In this regard, please note that we do not collect, store, or have access to your biometric data, including face identification or fingerprint information. We affirm that you are solely responsible for the accuracy and truthfulness of your Personal Data shared with us, and the Company is not responsible or accountable for verifying the authenticity of your Personal Data. Your Personal Data will be verified by lending/ non lending partners as per their internal policies who will be providing end services to you We and/or our lending/ non lending partners may also collect information made publicly available through other third-party websites including through online or offline databases that are otherwise legitimately obtained and are subject to the third party's terms of use and/or privacy statement. We only collect and use such information from you that we consider necessary for achieving an efficient and safe experience that is customized for your needs and expectations which in turn helps us to offer tutorials and works that are most likely to meet your needs and demands. Company shall use technologies such as cookies, clear gifs, log files, and flash cookies for several purposes, including to help understand how you interact with our Website, Applications and Services to provide a better experience. The Company may gather any non-personal information regarding how many people visit the Website/ Applications, browser type, pages visited by them, their IP address, versions, operating systems, Device ID, Device manufacturer and type, Device, usage statistics, default communication applications and other technology on the Devices used to access the Website/ Applications, maximum products purchased by a user etc. Such information shall also include all such Personal Information collected and stored by the Company that undergoes the process of de-identification and is no more identifiable to you or any natural person (hereinafter referred to as “Non-Personal Data”). The Company may also collect Non-Personal Data that you voluntarily provide, such as information included in response to a survey and/or questionnaire.

• verify your identity;
• enhance your experience, analyze your interaction with the Services and issue any corrective measures if required;
• for any legal and regulatory/ audit purposes (for example, in response to subpoenas, summons, court orders, and law enforcement or governmental requests or investigations), and to protect our legal rights or the rights of others (for example, by working to reduce the risk of fraud or misuse of the Service);
• respond to your queries about the Services;
• deliver to you any notices, alerts, or communications relevant to your use of the Services;
• customize/ personalize the works being offered including but not limited to the financial health card and bureau score;
• to monitor, analyze, and describe usage patterns and performance of the Service, including aggregate metrics such as total number of visitors, traffic, and demographic patterns;
• to conduct system administration and system troubleshooting and to diagnose or fix technology problems;
• aggregate the anonymized information from registered users to perform market research, project planning, product development, troubleshoot problems, analyze user behaviour, marketing purposes, and promotions for the Company and its authorized business partners;
• to enforce this Policy and/or the terms of Service or any other related policy;
• to introduce new features or products/services. These might be our own offers or products/services, or third-party offers or products/services with whom the Company has a tie-up;
• administer our obligations under any agreement with our business partners;
• utilize your information for internal analysis and offer location-based services, such as advertising, search results, and personalized content;
• assist in the facilitation and delivery of Services by us or our business partners, process payments and applications, and communicate with you regarding products, services, and promotional offers;
• enhance our Website, Applications and/or prevent or detect fraud or abuses on our Website, Applications, and/or allow third parties to perform technical, logistical, or other functions on our behalf. We may integrate information obtained from you with data about you received from third parties;
• dispatch notices, communications, and suggest services of potential interest to you, update our records, and manage your accounts, including displaying content and customer reviews;
• to send general notices or important updates about your account, seek your feedback or opinions, and inform you about special deals and offers;
• with your consent, the Company may access your mobile device id, including the camera, to facilitate services, enhance accessibility, and facilitate logins to Applications for the various services you opt for;
• for lending services, we do not access your non-public personal contacts or financial transaction SMS data. For non-lending services, we may have limited access to your financial transactions, SMS data but only with your explicit and prior consent; and
• If you are a vendor or employee of the Company, we use your Personal Data for the purpose of making payments, payrolling and deducting taxes;

We have physical, electronic, and procedural safeguards that comply with the laws prevalent in India to protect your Personal Data. We seek to ensure compliance with the requirements laid down under the Act and the Rules to ensure the protection and preservation of your privacy. 

Our Services are intended for adults only and accordingly, the privacy policy for minors is not being provided. You must be 18 years of age or older and an Indian resident to register and use our platform. 

We will take appropriate steps to protect your Personal Data from misuse, unauthorized access and/or wrongful disclosure using appropriate security measures based on the nature of the data collected and the manner of processing the same. We will store your Personal Data for such period as may be required and permitted by Applicable Law or for a period necessary to satisfy the purpose for which the Personal Data has been collected. These periods vary depending on the nature of the information and your interactions with us. We retain your Personal Data only for legitimate purposes as specified in this Policy.   We will retain your Personal Data only for the period during which the purpose for its usage exists as per this Policy, after which we undertake to dispose of the same in the manner complaint with the Applicable Law except for any record retention requirements arising under the Applicable Law.  As a User, you always have the right to request in writing for deletion of your Personal Data at any time, however, this may affect the quality of the Services being provided by us, or this may also limit your ability to use our Services or in certain circumstance, you may not be able to use our Services after deletion of your Personal Data.

A cookie is a very small text document, which often includes an anonymous unique identifier. These are sent to your browser from the websites that you visit and are stored on your device's internal memory. We use cookies on the Website which helps us to provide information, which is targeted to your interests, keep track of your preferences, evaluate the effectiveness of the Website, analyze trends, identify logged in or registered users and administer the Website. This helps us to provide you with good experience when you use the Services on the Website and allows us to improve such services. We further use cookies to determine which parts of the Website are most visited, and what difficulties our visitors/ users may experience in accessing the Website. Your use of the Website or Services with a browser that is configured to accept cookies constitutes acceptance of ours and any third-party cookies.

The security of your Personal Data is important to us, and your Personal Data is secured as per reasonable security practices and Applicable Law of the Country. You may please note that the Company adheres to IS/ISO/IEC 27001 standard for collection of data. Any information/ data collected by the Company will be stored in servers hosted in India, in compliance with the Applicable Law.  The Company uses industry standards, and physical, technical, and administrative security measures to keep Personal Data confidential and secure and the Company will not share your Personal Data with third parties, except as otherwise provided in this Policy. We take robust precautions to protect your Personal Data from loss, misuse, unauthorized access or disclosure, alteration, or destruction. We employ many different technological and procedural security measures such as encryption, passwords, and other appropriate security measures which are reasonably designed to help protect your Personal Data from and against any loss or misuse and unauthorized access or disclosure by individuals inside and outside the Company. However, no method of transmission over the internet, or electronic storage method is 100% (one hundred percent) secure and reliable, and we cannot guarantee its absolute security. You therefore agree that any security breaches beyond the control of our reasonable security practices are at your sole risk. You may note that the Company is not responsible in any manner whatsoever for the unauthorized use of your Personal Data or for any lost, stolen, compromised passwords, or for any activity in your account including by way of unauthorized password, due to the reasons attributable to you, or if such unauthorized act is connected with your act(s) or omission(s) or your use of the Device. Also, the Company will not be liable for any breach of security or for any actions of any third party or events which are beyond its reasonable control including but not limited to computer hacking, unauthorized access to data and storage devices, breach of security and encryption, crashes, acts of government, and bad internet connection. 

We use other companies, agents, or contractors, partners ("Service Providers") to perform services on our behalf or to assist us with the provision of Services to you. We engage Service Providers to provide marketing, advertising, communications, infrastructure, and IT services, to personalize and optimize our Services, to process credit card transactions or other payment methods, to provide customer service, to collect debts, to analyze and enhance data (including data about users’ interactions with our Service), and to process and administer consumer surveys. You acknowledge and agree that while providing such services, the Company may be required to transfer some or all your Personal Data and these Service Providers may have access to your Personal Data. We do not authorize them to use or disclose your Personal Data except in connection with providing their services.  You acknowledge and agree that we may transfer and/or disclose your Personal Data if we believe that such action is necessary to:

• comply with any legal process served on us or affiliated parties or other legal requirement of any governmental authority;
• protect the safety of users of the Website, us, or third parties affiliated with us;
• mitigate our liability in an actual or potential lawsuit;
• help investigate or prevent unauthorized transactions or other illegal activities; and
• protect and defend our rights or property, the Website, the users of our Website, and our affiliated parties.

The Company will transfer your Personal Data only for the purposes specified in this Policy to such entities and/or body corporates which ensure at least the same level of data protection, as maintained by the Company and provided for under the Act and/or Rules. The Company may transfer your Personal Data only if it is necessary for the performance of the lawful contract between the body corporate or any person on its behalf and the User, or where the User has consented to such data transfer or is required under Applicable Law.  However, a third party to whom the Personal Data is transferred by the Company is only authorized to use the data for legitimate business purposes and not for any other unlawful business. Accordingly, you acknowledge and agree that your Personal Data may be disclosed by us in connection with the Services being provided to you, including in the following manner: 

• Legal obligation: You hereby authorize us to transfer and/or disclose any Personal Data provided by you to any law enforcement and other government officials or governmental bodies as we believe appropriate or necessary to comply with our legal obligations or for investigation of fraud or any other activity which may expose us or you to any legal liability.
• Information disclosed to third party service providers: We may contract with various third parties for the provision and maintenance of our Website, Applications, Services/ offerings and our business operations, and we may need to transfer and/or share your Personal Data and data generated by cookies with these vendors and service agencies. We do not authorize them to use, transfer, or disclose your Personal Data except in connection with providing their services to us.
• Information shared with our business partners: We may transfer, disclose and/or share your Personal Data with our business partners that are committed to serving your online needs and related services for purposes defined under this Policy or while making transactions specifically requested by you, which are ultimately connected with the Services being provided to you.
• Links to external service providers: Our Website and/or Applications may contain hyperlinks to other websites that may collect any Personal Data about you. We have no control over any websites or resources which are provided by companies or people other than us, and we are not responsible for the privacy practices or the content of those external websites, and your use of any such other website or applications is subject to the terms of use and privacy policy located on such external websites or applications. We recommend that you check the external website’s privacy policies to see how the operators of such websites will utilize your Personal Data.
• Internal departments: We may share, transfer and/or disclose your Personal Data with the internal investigation department of the Company or agencies appointed by us for investigation purposes. Also, if you are an employee, vendor/supplier of the Company, your Personal Data may be shared internally with the relevant departments on a need-to-know basis, subject to compliance with Applicable Law..
• Credit Data Handling and Privacy: We are fully committed to protecting your credit data and upholding your privacy in strict compliance with the CICRA Act, 2005, and other relevant data protection laws. Any credit-related data is collected only with your explicit, informed, and specific consent, solely for the legitimate and specified purpose for which it was obtained (e.g., assessing your eligibility for our services). Your data will be securely stored and retained only for this defined purpose, ensuring it is never used for any unauthorized activity. Specifically, such data will be securely and irreversibly deleted from our live systems after 150 days (or 5 months) from the date consent was given, or once the intended purpose has been fulfilled, whichever occurs earlier. Additionally, if you submit an express request for deletion, we will promptly and securely remove your credit data from our live systems. Please note that this data is also removed from our backups, a process which may take up to 7-8 days to complete. Consequently, under no circumstances will your credit data remain in our systems for more than 5 months and 8 days, which is still well within the period for which your consent was granted. We maintain a firm policy: we do not share your credit data with any third party under any circumstances.

Any Personal Data collected, used, stored, processed, or transferred by the Company while providing the Services to you will be subject to your explicit consent given by you while visiting the Website and/or Applications to avail our Services/ offerings in relation to the lending and/or non-lending segments. You understand that for the purpose of providing the Services, the Company may share your Personal Data with certain third parties, including such body corporates that provide the loans/ credits in connection with the Services, and you expressly agree to such Personal Data being shared with them. A list of third parties with whom the Company is permitted to share the Personal Data is as follows: (i) group companies; (ii) vendors; (iii) service providers; (iv) data processors; (v) banks; (vi) financial institutions such as non-banking financial companies, credit bureaus; (vii) telecom companies; and (viii) statutory bodies. If you do not agree with the terms of this Policy, please refrain from using the Website/ Applications.  Processing your Personal Data including but not limited to, collecting, storing, deleting, using, combining, sharing, transferring, and disclosing, will take place in India. If you reside outside India, your Personal Data will be transferred, processed, and stored in accordance with the Applicable Law of India.

• Accessing information: You have a right to request a summary of the Personal Data being processed by the Company including the processing activities undertaken by the Company in relation to such Personal Data. 
• Option to not provide the Personal Data: You may choose not to disclose Your Personal Data to the Company. However, please note that the Company may require some Personal Data to permit you to register with it or for you to avail yourself of any or all the features of our Platforms. As stated above, if you decide not to provide some Personal Data, your ability to use our any of the Platforms may be limited. 
• Data correction: You will always have an option to access your account and your Personal Data to view, add, update and/or alter your Personal Data shared with us.
• Data erasure or deletion: You will have a right to request for deletion or erasure of any of your Personal Data shared with us.
• Deactivation: You have the right to request deactivation of your user account maintained with us. Once deactivated, we will neither collect nor process your Personal Data, except as set out in this Policy or as required under the Applicable Law.
• Consent withdrawal: You have the right to withdraw your consent for the collection, handling, or processing of any of your Personal Data at any time. Upon receiving a formal request for consent withdrawal, our privacy officer will manually verify your identity and invalidate your consent within our systems. For credit information, this will trigger its automatic and irreversible deletion as per our data retention policies. We confirm that no credit information will be held by us post-deletion. Please note that withdrawing your consent may impact the quality of the services we provide to you. While your credit information will be completely purged, we may continue to process and hold some of your other personal information (not credit-related, and not fetched from any bureau) if such processing is required or authorized under applicable law in India, or for other legitimate business purposes such as account management or legal obligations.
• Grievance redressal right: The grievance redressal mechanism is set out in paragraph 17 of this Policy.
• Nomination right: User has a right to nominate any other individual who, in the event of death or incapacity, can exercise rights on his behalf.
• Making available privacy policy in another language: If you wish to read and view the privacy policy in any other language, we will be happy to arrange for the same. However, in the event of any discrepancy or conflict between the English version of the privacy policy and versions in other languages, the English version will prevail over any other translated versions.

If you would like to exercise any of these rights, please contact our Data Protection Officer at the following:  

Name: Mohit Jain  

Email us at: dpo@www.finfinity.co.in.in  

Contact: 9930819090

The Company will have a period of 1 (one) month to respond to any of your request(s) above. Please note that exercise of any of the above rights may affect the quality of the Services being provided by us, or this may also limit your ability to use our Services or in certain circumstance, you may not be able to use our Services after deletion of your Personal Data. Deleting your account by the Company may also result in termination of our Services to you. 

Subject to your prior consent, we may send periodic promotional or information to your email or mobile number registered with us. You may opt to discontinue such communications by following the opt-out instructions contained in the email.  We may require a reasonable amount of time to process any opt-out requests. If you opt out of receiving emails or communications on the mobile number about recommendations that we think may interest you, we may still send emails on a case-to-case basis.

This Policy elucidates the Company’s current data protection practices and policies. The Company reserves the right to update this Policy from time to time. The Company will notify you whenever there is a change in the Policy by posting a conspicuous notice on the Website/ Applications or by way of an announcement over the email or by pop-ups on the Website/ Applications regarding its then applicable data protection policies. The Policy shall come to effect from the date of such an update, change or modification. We encourage you to review this Policy periodically to stay informed about any changes. Your continued use of our Platforms or provision of data or information thereafter will imply your unconditional and absolute acceptance of such updates to our Policy. This Policy applies to all the Company’s platforms, including our desktop Website, mobile Website, and Applications.

While we are committed to protecting your privacy and securing your Personal Data in the manner as specified in this Policy, we neither promise nor warrant that your Personal Data will always remain private and secured. The Company neither warrants nor assures that the information provided on the Website and/or Applications is entirely accurate and error-free. In case of any discrepancies, Users are advised to verify the information by getting in touch with us. Information provided on our Website and/or Applications might get updated or changed from time to time, in such case it shall be the duty of the user to verify the contents of the Website and/or Applications.

Notwithstanding anything contained in this Policy or elsewhere, the Company shall not be held liable or be responsible to you for (a) any loss of profit, goodwill or business opportunities or any type of direct or indirect, incidental, compensatory, punitive, economic, exemplary, or any kind of consequential losses arising out of performance or non-performance of its obligations hereunder; (b) any actions or inactions of any third-parties that receive your Personal Data; and (c) any loss, damage, or misuse of your Personal Data, if such loss, damage or misuse is attributable to a Force Majeure.  In respect of the above, the term “Force Majeure” means any event that is beyond the reasonable control of the Company, including but not limited to acts of god, fire, flood, explosion, sabotage, civil commotion, strikes, lockouts or industrial action of any kind, riots, insurrection, war, computer hacking, civil disturbances, unauthorised access to data and storage device, breach of security and encryption, crashes, epidemic, pandemic and/or any other similar events not within the control of the Company.

This Policy shall be governed by and interpreted and construed in accordance with the laws of India. The place of jurisdiction shall exclusively be in Mumbai, Maharashtra. 

If we receive any formal written complaints (please refer to the Grievance Redressal section below), we shall contact the User who made the complaint to solve the problem at the earliest. We shall work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our User/s directly. The Company has appointed a Grievance Officer to redress customer grievances relating to any complaints under this Policy. Details of the Grievance officer are provided below:

Name: Mr. Mohit Jain

Address: 305, Wellington Business Park 2, Marol, Mumbai, Maharashtra -400059

Email: grievance.redressal@www.finfinity.co.in.in

Contact: 9930819090

Please also visit our Terms of Services section which establishes the use, disclaimers, and limitations of liability governing the use of our Services. You can access the same by clicking here: https://www.finfinity.co.in.in/terms-of-use.