Privacy Policy

We, at FINLAB AI Solutions Private Limited (“Summup” or “We”) understand Privacy and its value. Therefore, it is all the more important for us to make YOU (“You” or “Customer” or “User”), the User of the website https://summup.in (the “Website”) and its associated mobile applications, Summup (“Application”) (collectively, the “Platform”) understand the reason behind collection of your information and its usage and the manner in which we collect, use, store and share information about you (“Privacy Policy”). This Privacy Policy has been prepared in compliance with:

a. Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011;

b. Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021

c. Guidelines on Digital Lending issued by the Reserve Bank of India (RBI), 2022;

d. Other applicable acts, regulations and rules which requires the publishing of a privacy policy for handling of or dealing in personal information including sensitive personal data or information and all applicable laws, regulations, guidelines provided by applicable regulatory authorities including but not limited to the RBI.

This Privacy Policy is incorporated into and at all times is subject to and is to be read in conjunction with the Terms of Use of the Platform.

1. USER ACKNOWLEDGEMENT AND CONSENT

User acknowledges that by accessing the Platform, User expressly consents and confirms to collection, maintenance, usage, handling, storage and disclosure of User information, including sensitive personal data, by Summup, in connection with the loan facilitation services we offer to you through the Platform ("Services"), in accordance with this Policy.

You acknowledge that you have the option to not provide or agree to the collection of personal data. If a User chooses to not grant us access to such personal data when requested, we will not be in a position to provide the User with the Services. In such an event, we encourage you to stop using the Services and accessing the Platform. In addition to this, in the event you do not consent to our access of your personal data, we may have to terminate, suspend or limit your access to the Services or Platform or part thereof, as may be the case.

2. PURPOSE OF COLLECTION OF INFORMATION

Our primary goal in accessing, collecting and using your information, is to provide you with a safe, efficient, smooth and customized experience of our Services. More importantly, we only collect and process basic minimal personal information of the User that we consider necessary for providing the Services and enabling your use of our Platform.

In general, you can browse the Platform without disclosing your identity or revealing any personal information about yourself. However, in order to avail the Services you will be required to provide us with certain basic minimal information in connection with the Services.

3. WHAT WE COLLECT AND HOW WE USE YOUR PERSONAL DATA

3.1. Summup collects the following types of data sets from you:

(a) Personal data collected directly from you

This type of data is the personal data you provide us. You consent to provide us access to such personal data through your continued use of the Services or through interaction over the Platform. This includes:

i) Identity and Profile-related Data: This includes personal information concerning the personal or material circumstances of an identified or identifiable User, e.g. name, gender, date of birth, marital status, family details, employment verification information and other similar details shared via the Platform.

ii) Contact data: This includes your email addresses, phone numbers, and postal address.

iii) KYC data: In connection with the Services and your use of the Platform, we may also require you to share, or we may collect identification documents issued by government or other authorities to you, including details of or pertaining to Aadhaar number/card, PAN number/card, voter ID, KYC identifier and/or ration card.

iv) Financial data: This will include your past credit history, income details, details of loans issued, or otherwise applied for through the Platform, payments and repayments thereof, your bank account details and bank account statements.

(b) Personal data collected through your use of the Platform and from your device

This type of data is the personal data collected through your use of the Platform and Services, and ancillary data required for the purposes of fraud detection. The information that the Platform collects, and its usage will solely depend on how you manage your privacy controls on your device. It includes:

i) SMS Data: We may collect, transmit and store SMS data from your phone to verify and analyse your financial position, to determine your cash flow, credits, income, and spending pattern. Please note that such data is limited to details of the transactions contained in the SMS. Personal SMS data or sensitive information such as OTP, personal SMSs, account details, etc is filtered out and not stored.

ii) Device Data: We may collect IP addresses, SDK version and mobile network information including carrier name, SIM Serial and SIM Slot, your profile information, time zone settings, location and device information for the purpose of onboarding. We collect information about your device to undertake fraud detection, provide automatic updates and additional security so that your account is not used on other people's devices.

iii) Usage Data: We track certain information about you based on how you use the Platform and Services. We use this information to do research on our Users' demographics, interests, and behaviours to better understand, protect and serve our Users and improve our Services. This information is compiled and analysed on an aggregated, anonymized basis.

iv) Transaction data: This includes details of transactions that may occur through the Platform or in connection with the Services. For example, transaction data may include the Services you have sought or availed through the Platform or confirmations of such Services.

v) Marketing and communications data: This includes your preferences in receiving marketing messages from us and our third parties and your communication preferences.

(c) Personal Data Collected from Third Parties

This type of data is personal data about you received from various third parties and public sources including our third-party service providers for advertising and User analytics purposes, and other publicly available sources in connection with our provision of Services to you, or in connection with your use of the Platform or Services that you choose to avail. Please note that we do not have any control over personal data that you may choose to make publicly available. For example, if you post reviews, comments, or messages on public sections of the Platform or on an application store (such as the Play Store), you do so at your own risk. We are not liable for any third-party misuse of such data.

4. USE OF PERSONAL DATA

4.1. By using our Platform and submitting your personal data to Summup, you expressly acknowledge and consent to the use of such information in a manner specified under this Policy. Such personal data can be used for various purposes including:

(a) Registering you as a User of the Platform and verifying User identity;

(b) Facilitating User's usage of the Platform and our Services;

(c) Managing our relationship with you, including notifying you of changes to any Services or any offer which may qualify time to time;

(d) Extending loan and other financial products or financial services to the User from regulated entities including but not limited to banks, non-banking financial companies or "NBFCs", other financial partners, etc ("Lending Partners");

(e) Ensuring compliance with all legal obligations of Lending Partners, vis-à-vis Know-your Customer, Prevention of Money Laundering, CKYRC requirements, etc for the purposes of facilitation of the loan/financial services;

(f) For fraud prevention and detection;

(g) Sending User surveys and marketing communications that Summup believes may be of User's interest;

(h) Diagnosing technical problems, providing support and helping Users in addressing and troubleshooting problems;

(i) Sending and receiving communications, showing advertisements, notifications and making promotional offers;

(j) Preparing reports, review and filing as per applicable laws;

(k) Contacting Users regarding Lending Partners and the various other financial products or financial services being facilitated through Summup, third party services and offers;

(l) Understanding User preferences, requirements;

(m) Permitting User to participate in interactive features offered through the Platform;

(n) Improving the content, our business and delivery models and protecting the integrity of the Platform;

(o) Increasing/improving the Services offered on the Platform;

(p) Ensuring compliance with all applicable laws.

(q) Responding to court orders, establishing or exercising our legal rights, or defending ourselves against legal claims;

(r) Performing our obligations that arise out of the arrangement we are about to enter or have entered with you; and

(s) Enforcing our Terms.

5. HOW YOUR PERSONAL DATA IS SHARED

5.1. Except as required under applicable laws or pursuant to a court/government order, any information or data shared by us with third parties shall be undertaken after obtaining your explicit consent, solely to render the Services to you.

5.2. We will share your information with third parties to facilitate the provisioning of Services by us to you only in such manner as described below:

(a) We may disclose your information to our Lending Partners on the Platform to facilitate the financial services for you;

(b) We may disclose your information to our third-party service providers for providing the Services as detailed under the Terms & Conditions;

(c) We may share your information with our third-party partners in order to conduct data analysis in order to serve you better and provide services on our Platform;

(d) We may disclose your information, without prior notice, if required under any law or if we are under a duty to do so in order to comply with any legal obligation or an order from the government and/or a statutory authority, or in order to enforce or apply our terms of use or assign such information in the course of corporate divestitures, mergers, or to protect the rights, property, or safety of us, our Users, or others.

(e) We may share your data with our affiliates and/or group companies for data processing and analysis;

(f) We and our affiliates may share your information with another business entity should we (or our assets) merge with, or be acquired by that business entity, or re-organization, amalgamation, restructuring of business for continuity of business.

5.3. If you fail to provide consent for sharing of such data when requested by us, we may not be able to provide the Services to you.

5.4. List of entities with whom your information is shared can be assessed at https://summup.in/digital-lending-partners.

6. COOKIES

6.1. Summup may use "cookies" as required on the Platform. "Cookies" is a term generally used for small text files a website uses to recognize repeat users, facilitate the User's ongoing access to and use of the site, allow a site to track usage behaviour and compile aggregate data that will allow content improvements and targeted advertising, preferences etc. Cookies themselves do not personally identify the User, but it identifies User device. For the purpose of this Policy, Users are informed that cookies also exist within mobile applications when a browser is needed to view certain content or display an advertisement within the application. Generally, cookies work by assigning a unique number to the computer that has no meaning outside the assigning site.

6.2. Users are being made aware that Summup cannot control the use of cookies or the resulting information by advertisers or third parties hosting data on Summup's Platform. If Users do not want information collected through the use of cookies, they may change the settings in the browsers that allows them to deny or accept the cookie feature as per User discretion and in the manner agreed by them.

7. DATA PROTECTION AND SECURITY

7.1. Pursuant to Information and Technology Act, 2000 and Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, Summup endeavours to protect the sensitive personal and personal data of the Users.

7.2. We store and process your personal information on cloud servers located in India. Some of the safeguards we use are firewalls and bit data encryption using SSL, and information access authorization controls. We use reasonable safeguards to preserve the integrity and security of your information against loss, theft, unauthorized access, disclosure, reproduction, use or amendment. To achieve the same, we use reasonable security practices and procedures as mandated under applicable laws for the protection of your information. In the event of a security breach, we use reasonable security standards and procedures as per our internal policies and applicable laws for the protection of your information.

8. YOUR LEGAL RIGHTS

8.1. Data Storage and Revocation of Consent

We will store your information and/or data for such period as may be required by Summup or Lending Partner to (i) enforce or enable the Lending Partner to enforce its legal rights and obligations against you; (ii) to ensure compliance with its obligations and responsibilities or the Lending Partner's obligations and responsibilities under applicable laws, as specified by the Reserve Bank of India.

You may, however, withdraw your consent at any time. Such a request shall be complied with by Us subject to the applicable laws and the terms of the loan availed through the Platform. You further understand and agree that neither the repayment of a loan/financial facility, nor the deletion of your account with the Platform, automatically rescinds the consents you have provided to us under the Privacy Policy.

8.2. Data Retention You agree and acknowledge that your personal data will continue to be stored and retained by us as required or permitted by applicable laws or as required for defending future legal claims against us or our Lending Partners.

8.3. Data Deletion All the other details will be deleted upon your request for the deletion of the data, provided there is no active loan or Service being availed by you.

8.4. Data destruction protocol You can request the erasure of your personal data. This enables you to ask us to forget personal data. We shall comply with any request, subject to applicable laws and the terms of the loans that are sanctioned through the Platform.

9. UPDATE USER INFORMATION

Users are required to update their information available with Summup as and when there are any changes. Users are also entitled to review the information provided and ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient be corrected or amended as feasible.

10. TRANSFER OF PERSONAL DATA

Please note that all your data, including financial data, is only stored on systems located in India. We shall not transfer your personal data outside India.

11. THIRD-PARTY WEBLINKS

User acknowledges that the Platform may contain links to other websites. If a User clicks on a third-party link, the User will be directed to that website . Note that these external sites are not operated by Summup. Therefore, it is strongly advised that Users review the privacy policy of these websites/external links. Summup has no control over and assumes no responsibility for the content, privacy policies, or practices of any third-party sites or services.

12. CHANGES TO PRIVACY POLICY

In the event Summup modifies this Privacy Policy, the same will be updated on the Platform. In case of any material changes to the Policy, the Users will be notified by means of a notice on the Platform prior to the change becoming effective. The Users are encouraged to periodically review this page for the latest information on Summup's privacy practices.

13. GRIEVANCE REDRESSAL OFFICER:

Name: Ms. Shuchi Jain

Address: Awfis, 6th Floor, Suncity Success Tower, Golf Course Extension Road, Sector-65, Gurgaon - 122005

Email: support@summup.in

Call at: 0124-4185523 (Lines are open Mon-Fri from 9:30am to 6:30pm)

If you have questions, concerns, or suggestions regarding our Privacy Policy, we can be reached using the contact information on our contact us page or at support@summup.in