Privacy Policy

INTRODUCTION

Easy Platform Services Private Limited (“Easy”, “We”, “Us”, “Our”) is the owner of the website (“www.getzype.com”) (“Website”) and the android mobile application, including any other application or software run under the brand name – ‘Zype’ (“Zype”) (Website and Zype are hereinafter collectively referred to as “Platform(s)”). Easy (i) connects borrowers with its affiliates, financing partners, third-party service providers and lenders or their lending service providers (“Third Party(ies)”); (ii) monitors the loans; and (iii) assists in recovery of loans (collectively referred to as “Services”).

This privacy policy (“Policy”) discloses the practices and policies adopted by Easy while accessing, collecting, storing, retrieving, disclosing, transferring, or using information it may receive from its users (“You”, “Your”, “Customer”) who access/ use the Portal(s) (defined below) to receive the Services. Capitalised terms used but not defined in this Policy shall have the meaning as set out in Easy’s Terms and Conditions https://stagingv2.zypecard.co.in/terms-conditions/ .

This Policy is published in accordance with the applicable provisions of law, including the Information Technology Act, 2000 (“IT Act”) and the rules made thereunder, and the Guidelines on Digital Lending issued by the Reserve Bank of India dated September 2, 2022 (“DLG”). We request You to go through this Policy and the Terms and Conditions https://stagingv2.zypecard.co.in/terms-conditions/ carefully before You decide to access/ use the Portals (defined below) and receive the Services. We encourage You to familiarize yourself with Our Policy and let Us know if You have any further questions. Please note that Easy reserves the right in its sole discretion to remove any content or data, information or material it shares on the Portals, from time to time.

The information received from You while accessing/ using the Portals (defined below) through the (i) Website; (ii) Zype; or (iii) other facilities, including the Zype call-center facility (“IVR”) (Website, Zype and IVR are collectively referred to as the “Portal(s)”) will be utilised in a manner as set out in this Policy.

INFORMATION WE COLLECT

To register as a user on the Platforms, You will be required provide Us with information about yourself, required as part of Our Customer identification and Customer due diligence process. The Platforms may access, collect, store, use, disclose or transfer the information required to provide You with customized services and You have explicitly consented to the same. Such information may include Your name, mailing address, phone number, PAN card details, Aadhaar card details, employment information, financial information such as bank account etc.

The Platforms may also access, collect, store, use, disclose or transfer the following information about You and by clicking/ confirming on the consent screen on the Platforms, You have explicitly consented to the same.

• Account Information: Self-declared information like referral code, email, photo, address proof and identity proof. Additionally, for availing loans/ credit facilities with the Third Parties:
  • Salaried individuals may have to provide: Employment details like company name, salary/offer letter on case-to-case basis, and the company email ID;
  • Self-employed individuals may have to provide: Self-employment details such as profession, work location and monthly income.
• SMS: We access Your transactional SMS to provide relevant services/ offers/ rewards basis Your consumption pattern and to facilitate the credit assessment to be undertaken by the Third Parties. You may have restricted access to the Platforms and the related services available on the Platforms, if You disable/ withdraw/ do not provide this access.
• Camera Access: We require access to Your mobile device camera for clicking Your selfie and to enable You to upload photos/ videos for KYC compliance and/ or for uploading any other necessary documents on the Platforms as part of Our on-boarding/ KYC compliance function. You may have restricted access to the to the Platform and the related services available on the Platform, if You disable/ withdraw/ do not provide this access.
• Location: We may access and monitor Your location to verify Your current address, to ensure/ check, serviceability of Our Services, and to prevent any fraudulent activity. We collect the location data from You in two ways: (i) on the basis of information provided at the time of on-boarding; and (ii) from Your mobile device when enabled by You to do so. We access this data only when Our Platforms are being used. You may have restricted access to the Platforms and the related services available on the Platforms, if You disable/ withdraw/ do not provide this access.
• Contact: We may periodically access Your contact(s) information to facilitate the credit assessment to be undertaken by the Third Parties and to provide You with access of additional features on the Platforms. We will not under any circumstance call or reach out to any of Your contacts for any matter related to Our Services. You may have restricted access to the Platforms and related services available on the Platforms, if You disable/ withdraw/ do not provide this access.
• Device Data: When You browse Our Platforms, We automatically receive Your device internet protocol (IP) address. This helps Us learn about Your browser and operating system, software, the date and time at which You visited the Platforms, the type of device being used (including the hardware models). This helps Us detect and prevent fraud. You may have restricted access to the Platforms and the related services available on the Platforms, if You disable/ withdraw/ do not provide this access.
• Files/ Media: We may require access to Your files/ media folder so that Your documents can be securely downloaded and saved on Your phone, and so You that can upload any required documents easily for quicker approval and disbursal of loan/ credit facility. This helps in providing a smooth and seamless experience while using the Platforms. We will not store any files from Your storage. We can only access the files You select in the folder. We may access only the meta data for the purpose of providing You with seamless access to loan/ credit facility. You may have restricted access to the Platforms and the related services available on the Platforms, if You disable/ withdraw/ do not provide this access.
• Third party information: We may share the aforementioned information for the purposes mentioned above, in accordance with applicable legal requirements for lawful business purposes of Easy or when it is necessary for the performance of the legal contract/ agreement to which You are a party. We work closely with other entities, including, credit information bureaus, account aggregators, business partners, technical sub-contractors, analytics providers, search information providers, etc. and may lawfully receive information about You from such sources. Such information/ data may be combined with information/ data collected on the Platforms to provide You with a customised user experience.

The aforementioned information, as provided by You, accessed from Your device or received from the aforementioned third parties, is hereinafter collectively referred to as “Collected Information”. Please note that We may require You to share further information, at a later date, to confirm the veracity of Your Collected Information or pursuant to any additional features added to the Platforms or for compliance with applicable law.

All the information that You provide to Us is voluntary, including the sensitive/ personal information, forming part of the Collected Information. You understand that We may use the Collected Information, including such Collected Information which may be designated as ‘sensitive personal data or information’ under the IT Act and the rules made thereunder, for the purpose of providing You the Services in accordance with the terms of this Policy for which You have provided Your consent. We shall use the Collected Information, in a way that is compatible with and relevant for the purpose for which it was collected, as set out in this Policy, or authorized by You.

We are and will be in compliance with the applicable requirements stipulated under the Prevention of Money-Laundering Act, 2002 and its rules, including the Prevention of Money-Laundering (Maintenance of Records) Rules, 2005, as may be amended from time to time. It is further clarified that, Your information, if shared by Us within Our group, subject to compliance with applicable laws, for the purposes of client due diligence and money laundering and terror finance risk management, will be undertaken keeping in mind adequate safeguards on the confidentiality and use of information exchanged, including safeguards to prevent tipping-off.

For users who have registered to be on the mailing list, their Collected Information is kept until We are notified that they no longer want their information stored. Customers who supply Us with their telephone numbers may receive communication from Us via telephone, text message or emails, pertaining exclusively to new Services or any upcoming events. If You do not wish to be on Our mailing list/SMS/WhatsApp or any other advertisement, You can let Us know of Your updated preferences by either emailing Us at info@stagingv2.zypecard.co.in or choosing “unsubscribe” option or the prescribed option.

If You are no longer interested in sharing the Collected Information, please e-mail Your request at: support@stagingv2.zypecard.co.in Please note that it may take about 72 (seventy-two) business hours to process Your request. Further, please note that there might be latency in deleting/ forgetting the Collected Information from Our servers and certain backed-up versions might exist even after deletion.

Notwithstanding anything contained herein, please note that Easy will continue to retain Collected Information provided by You (a) until You specifically request Easy to destroy such Collected Information or (b) for as long as Your registration with Us is valid and the outstanding amount(s) in respect of the loan(s) availed by You are due and payable to the Third Party or (c) for such period as may be necessary to comply with applicable laws or (d) till final settlement/ outcome of any disputes with You or the Third Party, as the case may be or (e) to enforce/ exercise Our rights under the contract/ agreements entered into between Us and You/ the Third Party.

DISCLOSURES

We will share Your Collected Information internally with those staff members of Easy who need it to carry out Your instructions regarding the receipt of marketing information, loan/ credit facility processing, recovery of loan/ credit facilities.

Any personal information, forming part of the Collected Information, may be used to allow You to login to Your account or to resolve specific service issues, inform You of Our new Services/ features, for IVR verification, or to communicate with You in relation to Your use of the Platforms. Other information, forming part of Collected Information, may be used for-

1. Our business purposes and this may include the viewing or advertising of services or relating to any associated services;
2. Analytical purposes, data usage;
3. Improving the Platforms, or Your user experience; and
4. Providing targeted advertisements to You.

We may share Collected Information with Third Parties, credit bureaus, call centres, payment gateways, authorised service providers, payment transaction processors or law enforcement agencies for the purposes mentioned in this Policy or if it is to help investigate, prevent or take action regarding unlawful and illegal activities, suspected fraud, potential threat to the safety or security of any Customer, or as defence against legal claims. We will keep the Collected Information confidential and limit access to those who specifically need it to conduct their business activities, except as otherwise permitted by applicable law. The Collected Information may be transferred to any destination within and/or outside India, to the extent permitted as per applicable law in force. Examples include delivering e-mail, analysing data, providing marketing assistance, providing search results and links (including paid listings and links) and providing Customer service.

To clarify, Easy may disclose Your Collected Information, without obtaining Your prior consent, in the following cases:

1. in the event it is required to do so by law, rule, regulation, governmental, legal or regulatory authorities and statutory bodies, who have appropriate authorisation to access the same for any specific legal purposes;
2. for compliance with any judgment or decree or order issued under any law for the time being in force in India, or any judgment or order relating to claims of a contractual or civil nature under any law for the time being in force outside India;
3. if agreed by You under the contract entered into between You and Easy;
4. any other purposes which may be required for the purposes set out under this Policy.

Any Third Party to whom such Collected Information is divulged, shall be subject to a duty of confidentiality, and will be required to comply with and take appropriate security measures to protect Your Collected Information, in line with applicable laws.

This Policy only addresses the use and disclosure of information We collect from You on the Platforms. Other websites/ apps that may be accessible through the Platforms have their own privacy policies and data collection, use and disclosure practices. If You click on the link to any such website/ app, We urge You to review such website′s/ app’s privacy policy. We are not responsible for the policies or practices of third parties.

COOKIES

We may set cookies to track Your use of the Portals. These are used to enhance Your experience while accessing Our Platforms. We use cookies to help Us identify who You are, so Your login experience is smooth each time. Cookies also allow Us to collect non-personally identifiable information about You, like which pages You visit and what links You click on. Use of this information helps Us to create a more user-friendly experience for all visitors. Please note that if You decline or delete these cookies, it may affect the services provided by Us.

ADVERTISERS

We may use Third Party advertisers to display advertisements on Our Platforms. In order to provide and improve Our Services and to share relevant ads with You, We use and disclose to Our advertising and analytics partners non-personally identifiable information that We collect, including cookie data, log data, and mobile data. These third-party websites/ advertisers/ internet advertising companies, sometimes use technology to send or provide data that appears on the Platforms. They automatically receive Your IP address when that happens. They may also use cookies, JavaScript, web beacons and other technologies to measure the effectiveness of their advertisements and to personalize content, for which We are not responsible, including in respect of the advertisement, information or content contained therein or the privacy practices employed by them. Please contact them directly for more information about their privacy policies and practices.

BUSINESS TRANSFERS

As We continue to develop Our Services and business, We might sell Our business units. In such transactions, Collected Information is generally one of the transferred business assets, but remains subject to the terms of the pre-existing policy(ies).

SECURITY INFORMATION

You can access Your personal identity details/ information on Our Platform through Your login credentials. We recommend that You do not share Your log-in credentials with anyone. Your Collected Information is stored on a secure server located in India, that only selected personnel contractors and authorised agencies have access to. We encrypt certain Collected Information using Secure Socket Layer technology to ensure that such Collected Information is safe, as it is transmitted to Us.

Notwithstanding the aforesaid, You understand and accept no data/ information transmission over the internet can be guaranteed to be completely secure. We cannot ensure or warrant the security of any information that You transmit to Us and You do so at Your own risk. Data pilferage due to unauthorized hacking, virus attacks, technical is possible and We take no liabilities or responsibilities for it.

GENERAL MATTERS

The authenticity and accuracy of the Collected Information, submitted by You, is Your responsibility. You are responsible for maintaining the secrecy, authenticity and accuracy of Your password, email address, and Collected Information submitted by You, at all times. Easy relies on You to disclose to it all relevant and accurate Collected Information submitted by You, and to inform Easy of any changes in respect of the Collected Information submitted by You. If You wish to make a request to correct or update any of the Collected Information submitted by You, You may submit Your request via email at support@stagingv2.zypecard.co.in.

SECURITY

We value Your online privacy and security while using the Platforms and receiving the Services available on the Platforms. We make every effort to ensure that the Collected Information submitted by You will not be misused. Our security measures and practices are in compliance with applicable laws and We shall continue to do so in the future. Notwithstanding the aforesaid, We cannot absolutely guarantee the protection of the Collected Information submitted by You.

CONFIDENTIALITY

Easy will take such steps as it considers necessary to ensure that Your Collected Information is treated securely and in accordance with this Policy. Notwithstanding the above, We are not responsible for the confidentiality, security or distribution of the Collected Information by Our employees, partners, agents and Third Parties outside the scope of Our agreement/ contract with such employees, partners, agents and Third Parties. Further, We shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond Our reasonable control including, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of internet service or telephone service of the user etc.

CONTACT US

If You have any questions or suggestions, You can contact Us at info@stagingv2.zypecard.co.in or write to Us at the following address:

1. Principal Officer

Easy Platform Services Private Limited

2^nd Floor, Dyna Business Park, Street No. 1, MIDC, Andheri (East) Mumbai-400093

2. Grievance Redressal Mechanism

If You have any complaints under this Policy or under the IT Act and the rules made thereunder, the DLG or any FinTech/ digital lending related complaints/issues, You can reach out to Us by following the procedure listed out under Our grievance redressal mechanism support@stagingv2.zypecard.co.in

DISPUTE RESOLUTION

In the event of any dispute, difference or claim arising out of this Policy, the same shall be settled in accordance with the laws of India through regular judicial process and the courts of Mumbai, India shall have exclusive jurisdiction.

CONSENT TO THIS POLICY

We keep the Policy under regular review and may update the same to reflect changes to Our privacy procedures and practices. We encourage You to periodically review this Policy for the latest information on Our privacy procedures and practices. Your continued use and accessing of Our Platforms will be taken as Your acceptance of this Policy or any updated version of this Policy.

By having consented to the terms of this Policy, You hereby provide express consent to Easy to access, collect, share, transfer, store, retain, transfer or use the Collected Information in accordance with the terms of the Policy.