1. GENERAL
1.1. We, KGIL Fintech Solutions Private Limited, a company registered under the laws of India, with registered
office located at Office No. 219 FLR 2 Gera, Imperium Rise Nr. Wipro, Infotech Park (Hinjawadi), Pune,
Haveli, Maharashtra, India, 411057 (hereinafter referred to as the “Company”, “SWIPELOAN”, “We”,
“Us” or “Our”) are committed to protecting privacy of Our Users (as defined hereinafter) and grant
importance to the confidentiality of user data over the internet.
1.2. This privacy policy (“Privacy Policy”) is an electronic record in the form of an electronic contract formed
under the Information Technology Act, 2000 and the rules made thereunder and the amended provisions
pertaining to electronic documents/records under various statutes as amended by the Information
Technology Act, 2000. This Privacy Policy does not require any physical, electronic or digital signature and
is a legally binding document between the User and Us. This document is published in accordance with the
relevant provisions of the Information Technology Act, 2000 read with the Information Technology
(Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 and the Information Technology
(Reasonable Security Practices & Procedures & Sensitive Personal Data or Information) Rules, 2011
(hereinafter referred to as the “SPDI Rules”) which collectively mandate intermediaries (such as
SWIPELOAN) to publish a privacy policy to provide for relevant information pertaining to collection, use,
storage, transfer/disclosure of Personal Information (as defined hereinafter).
1.3. The Privacy Policy together with other relevant terms available on Our Platform including the terms and
conditions published on the Platform (“Terms”) and other agreements between the user and the Company
(as may be applicable) is applicable to the Users of the Platform (hereinafter also referred to as “You”,
“Your”, “Yourself”). It is clarified that a reference to the term ‘Platform’ in this Privacy Policy shall mean
collectively Our website located at www.swipeloan.in and mobile application(s) under the name
‘SWIPELOAN’.
1.4. This Privacy Policy governs and sets forth the understanding in relation to the collection, usage, processing,
storage, and disclosure of information that You may provide to Us electronically in connection with Your
use or access of any of the services and facilities made available by Us on the Platform, including the lending
and credit services (the “Services”) We offer through collaboration with our Business Partner(s) (as defined
hereinbelow) available on the Platform. The User acknowledges that this Privacy Policy, Terms and such
other policies as may be framed by Us from time to time (as available at Our Platform) together form Our
collective agreement (“Agreement”) with the User in relation to Your use of the Platform and the Services.
1.5. SWIPELOAN collects various types of information from Users (collectively, the “Information Collected”
as further defined hereinafter) such as Personal Information including Sensitive Personal Information (as
defined hereinafter) and User Data (as defined hereinafter) from the User in various ways (as detailed herein
below) as per the applicable laws in India during and as a result of Your use, setting up of Your virtual User
account with Us when You successfully register on the Platform (“Account”) or Your access of Our
2Platform and Services. We collect and process the Information Collected in the aforementioned manner
subject to the Privacy Policy and User’s consent for the purposes mentioned in this Privacy Policy.
1.6. By visiting or using Our Platform and/or Services in any manner, You acknowledge and accept the practices
and policies outlined in this Privacy Policy, and hereby consent to Our collection and processing of
Information Collected (as elaborated hereinafter) in accordance with the terms herein and the Agreement.
You further acknowledge and accept that You are lawfully authorized to provide Your information to Us
and have the legal capacity to do so and to give Your legal consent for the collection and processing of such
information by Us. You further agree that such collection and processing of Your Information Collected in
accordance with this Privacy Policy shall not cause any loss to any other person. You acknowledge that
anything done, caused to be done, whether expressly or impliedly in contravention of this Privacy Policy
may render You liable for legal action. We shall not be held liable in any manner whatsoever if there is any
error or deficiency by Us in Our business transaction with You due to any information You provide Us
which is incorrect or provided in a manner contrary to this Privacy Policy or due to any withdrawal of Your
consent. You acknowledge and agree to indemnify and hold Us and/or Our employees, consultants,
directors, representatives and/or associates, etc. harmless from any complaints, legal proceedings or claims
filed or initiated by any third party against Us due to any breach by You of the terms of this Privacy Policy
through any act or omission attributable to You.
1.7. The Information Collected (including Your Personal Information and Sensitive Personal Information, as
may be applicable) is collected and processed by Us strictly in line with Our business purposes and to
provide You with useful features, including for provision and enhancement of Services, the operation of the
Platform and to respond to Your requests/queries in an efficient manner. If You are not agreeable to this,
please do not use this Platform and/or Services provided by Us. If You proceed to use this Platform and/or
Services provided by Us, You hereby consent to Our collection and processing of Your Information
Collected in the manner described in this Privacy Policy.
1.8. For the purpose of this Privacy Policy, any reference to the term “Personal Information” shall mean the
Personal Information or data of a User available with Us in electronic form (as elaborated below) and
includes information through which a User is capable of being identified, whether directly or indirectly (in
combination with other information available or likely to be available with Us in electronic form). Personal
Information will not include anonymized information that has been appropriately processed to make it non
identifiable in order to irreversibly prevent its identification.
1.9. Further, for the purpose of this Privacy Policy, any reference to the term “Sensitive Personal Information”
shall refer to the specific Personal Information of a User (as available with us in electronic form) which
qualifies as “sensitive personal information and data” in terms of the SPDI Rules. For reference, per the
SPDI Rules, “sensitive personal and data” includes Personal Information which falls in the following
categories: Passwords; Financial information such as bank account or credit card or debit card or other
payment details; Physical, psychological and mental health conditions; Sexual orientation; Medical records
and history; Biometric information. Users should note that We collect and process certain Sensitive Personal
Information (as elaborated below) of Users of the Platform, with consent from relevant Users and for certain
3purposes (as elaborated below) in relation to and for the purpose of the Services in accordance with the
Agreement.
1.10. It is clarified that reference(s) to the terms “User(s)”, “You”, “Your”, “Yourself” herein shall mean an adult
individual (above the age of eighteen years) resident in India, who has validly signed up/registered on the
Platform for availing the lending facilities and/or any of the other Services provided by the Platform and/or
has access to/use the features and functionalities of the Platform and who in connection with the Platform
and the Services may access or avail, share, transact, view, display, download or upload any of the
Information Collected on the Platform.
1.11. For the avoidance of doubt, subject to the Terms, SWIPELOAN does not provide Services to any individuals
below the age of eighteen years (“Minors”). We, accordingly, shall never knowingly seek Personal
Information (including Sensitive Personal Information) from a person who has not attained the age of
majority (under applicable laws in the jurisdiction such person is resident in). If You are a parent or guardian
and You are aware that a Minor in Your care has provided Us with any such information, without Your
knowledge and consent, please contact Our Grievance Officer in the manner provided in this Privacy Policy.
If We become aware that We may have collected any Personal Information from such persons, We will take
steps to remove that information from Our servers and/or to deactivate the relevant Account (if any)
associated with such persons as soon as reasonably practicable.
1.12. Further, it is clarified that reference(s) to “Business Partner(s)” shall mean the natural and legal person(s)
with which SPOTSBALL has a business arrangement or collaboration under a definitive agreement, in
relation to the functioning of the Platform and its Services, such as for facilitating, providing and/or
delivering certain functionalities on the Platform including any features or aspects of any Services provided
to User(s) on the Platform, as elaborated in the Terms. For reference, SPOTSBALL’s Business Partners
include Our qualified lending partners (including registered Banks and NBFCs/Non-Banking Financial
Companies), credit assessment partners, registered payment gateway/processing partners, billing, customer
support and information technology vendors etc.
1.13. Any capitalized term used but not defined in this Privacy Policy shall have the meaning attributed to it in
the Terms. For further information concerning SWIPELOAN and our Services, Users are encouraged to
refer to the Terms published on the Platform.
2. PROCESSING OF INFORMATION
2.1. The Information Collected including Personal Information shared with the Company shall be primarily
processed in India by the Company. However, Your information may also be processed in such other
jurisdictions where a third-party is contractually engaged by the Company or its Business Partner(s) to
process the data on their behalf in accordance with applicable laws. We will on commercially reasonable
basis require Our Business Partners and any other third-parties We engage and license to process the
Information Collected to adopt reasonable security standards to safeguard Your information/data, which
4shall be equivalent to the security standards maintained by Us in accordance with this Privacy Policy and
standards stipulated under applicable laws.
2.2. By agreeing to this Privacy Policy, You provide the Company with Your explicit consent to collect, share
and process Your Information Collected for the purpose(s) defined in this Privacy Policy. Further, You
acknowledge and accept that data protection regulations in India (or other jurisdictions as referred to herein)
may differ from those of Your country of residence.
2.3. In case You have any concerns in the processing of Your Personal Information (including Your Sensitive
Personal Information), please reach out to Our Grievance Officer in the manner specified in clause 10 in this
Privacy Policy.
3. INFORMATION COLLECTED
3.1. In the course of providing Services to You through the Platform and through Your use of the Platform, You
acknowledge and accept that We may collect User Data, Personal Information, Sensitive Personal
Information and other types of information listed herein below (collectively, the “Information Collected”)
from the User in the following ways: (i) as information supplied by User via the Platform; (ii) as information
automatically tracked during Users navigation on the Platform; and/or (iii) as communicated directly to Us
via e-mail or other electronic mode. You consent to Our collection and processing of that information.
3.2. We may collect Personal Information such as Your name (including Your username and individual name),
contact information (viz. phone number or email address or both) and Your postal address and location, at
the time of Your registration on the Platform. This type of information is primarily used for the purpose of
creation of Your User account (“Account”) with us for the Services. We also use such information to verify
Your identify and to maintain security and operation of Our Platform along with Our internal analytics and
reporting purposes.
3.3. We may further collect Personal Information such as Your name (including Your username and individual
name), contact information (viz. phone number or email address or both), postal address and location, and
employment information (viz. name and address of Your employer) at the time You seek/sign up to avail
lending or other Services on the Platform or during the process You avail the Services. We may also collect
Personal Information such as select contact data, files, SMS and images (to the extent required for the
Services) as available on Your device, during the provision of Services, upon taking your consent to access
such data. We collect such information strictly to facilitate the provision of the Services (such as by verifying
messages on Your device and allowing You to directly upload files on the Platform) and to enhance your
experience on the Platform. This type of information is primarily processed for the purpose of offering You
the Services through Our Business Partner(s) as well as to assess Your eligibility for the Services, to maintain
security and operation of Our Platform along with Our internal analytics, risk assessment and reporting
purposes.
53.4. Users should note that the Personal Information which We seek and collect from You for the purpose of the
Services may include certain Sensitive Personal Information. Specifically, We collect and process Your
financial details (including information in relation to Your bank account) for the purpose of processing Your
request for availing any of the lending facilities available on the Platform. We also collect Your identification
documents/details, typically Aadhaar and/or PAN, for the purpose of KYC or identity verification at the
time You apply for such Services. Such Sensitive Personal Information is collected solely and strictly to
verify the Your identity and accuracy of Your financial profile and credit score, to determine Your eligibility
for availing Services and for offering such Services. Users should note that such information is transferred
to our Business Partners for processing for the aforementioned purposes. You agree and acknowledge that
Our Business Partners may store and retain such Personal Information (including Sensitive Personal
information) in line with requirements under applicable laws and regulations in India and for the processing
this for the aforementioned purposes. It is clarified that such Your Personal Information (inclusive Your
Sensitive Personal Information) is not, however, retained or stored by us in line with statutory requirements.
SWIPELOAN retains only relevant portion of Personal Information (excluding Sensitive Personal
Information) of Users as is necessary for Us to carry out Our business operation, including to facilitate the
Services and fulfill the purposes set out herein, in accordance with applicable laws and this Privacy Policy.
For further information regarding how We store and secure Your information, please refer to clause 6 of the
Privacy Policy.
3.5. We may collect information and technical data about Your hardware devices with Your permission
automatically when You access or register on the Platform. For example, when You utilize Our Platform,
We may collect technical data and information about the type of mobile device/computer/laptop You use,
the browser You use, Your IP address and Your geographic region/location. We may also collect select
information about Your activity on the Platform, such as information about Your usage of Our Platform, as
well as information about how You interact with the Platform (collectively, “User Data”). We may combine
this User Data with other information, including Personal Information We have collected about You in order
to provide or enhance the Services and to offer features and functionalities on the Platform.
3.6. We collect communications exchanged between You and the Company and related information (such as
contact details associated with such communication) as well as any forms, data or information or documents
You send to Company or upload on the Platform in connection with the Services (i.e. as part of Your loan
application process on the Platform) in accordance with the Terms. Further, if the User communicates with
Us, for example, via e-mail, registers with Us or provides feedback or grievances to us in accordance with
the Terms, any information provided in such communication by User may be collected by Us for the purpose
of responding to the User, resolving Your queries and rendering Services and/or offering use of the Platform.
We collect and process information that You upload to, or choose to share through, Our Services and/or
Platform including submitted to strictly for the purpose of offering Services in accordance with the Terms.
3.7. We use the Information Collected (including the Personal Information and the Sensitive Personal
Information) for the Platform and Services in the manner mentioned in the Privacy Policy. Except for the
disclosures mentioned to be made in the Privacy Policy, We do not disclose Your or share Your Personal
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Information and Sensitive Personal Information in any manner. We do not publish Your Personal
Information and Sensitive Personal Information in any way.
3.8. You acknowledge and accept that We are not responsible for the authenticity of any Information
Collected, including the Personal Information and Sensitive Personal Information that You provide to Us.
You are solely and exclusively responsible for providing Us with information about Yourself that is true,
authentic, and correct in all aspects and particulars. If You provide inaccurate or false information to Us,
You shall be liable to indemnify and hold harmless the Company (and its officers, directors, contractors or
agents and any third party relying on the information provided by You) in the event You are in breach of
this Privacy Policy.
3.9. Correction, Update and Amendment of Information Collected: You shall have the sole responsibility to
intimate Us and request correction of inaccurate Personal Information maintained by the Company about
You. You may intimate Us in this regard by reaching out to Our support team via the following email
address: info@swipeloan.in. Upon receipt of a verifiable request from You, We will use commercially
reasonable efforts to correct the inaccurate Personal Information taking into account the nature of the
information and the purposes of the processing and in accordance with applicable laws and regulations.
4. TRANSFER AND DISCLOSURE OF INFORMATION
4.1. While We have implemented commercially reasonable physical, managerial, operational and technical
security measures (as detailed herein below) to protect the loss, misuse and alteration and to preserve the
security of the Personal Information (including Sensitive Personal Information) in Our care, the User
acknowledges and accepts that Information Collected on the Platform may be transmitted to third-party data
servers for the purposes mentioned herein below and processed subject to the terms and policies of such data
server.
4.2. We transmit certain Information Collected, including Your select Personal Information and Sensitive
Personal Information with Our Business Partners in the manner and for the purposes elaborated hereinafter
in clause 5. Principally, We may share Your contact and identification documents and information with Our
qualified KYC verification partner, Your financial details (including information about Your bank account,
income or transaction history as You may provide Us) with Our registered banking partners, Your payment
details with Our payment partner, and information Your provide for the loan application process with Our
registered partner NBFCs as well as associated qualified credit, collection and data processing agencies.
4.3. You acknowledge and accept that We may disclose Your information as We may deem necessary by sharing
such information with Our Business Partners who are responsible for fulfilling Services (and relative
facilities and payments) requested by Users on the Platform, in the manner and for the purposes described
herein. It is clarified that any transfer or disclosure of Your Personal Information to other third parties in the
manner mentioned herein will only be done by SWIPELOAN upon ensuring the relevant third party receiving such information has implemented an equivalent or higher level of security practices as We have
in the manner mentioned herein in accordance with statutory requirements.
4.4. Other than as specifically stated in this Privacy Policy, We will only disclose Your Personal Information in
the event it is required to do so by applicable law, rule, regulation, law enforcement agency, governmental
official, legal authority or similar requirements applicable to Us or if We, per Our sole discretion, deem it
necessary in order to protect its rights or the rights, property or personal safety of others; respond to claims,
to prevent harm to persons or property, to fight fraud and credit risk, or to enforce or apply the Privacy
Policy or Agreement, as and when deemed necessary. All transfers or disclosure of Your information
pursuant to this Privacy Policy and the Agreement will be undertaken for lawful purposes only.
5. PROCESSING OF INFORMATION COLLECTED
5.1. We may use and process the Information Collected including Your Personal Information, Sensitive Personal
Information and User Data along other information as shared and allowed to be stored by You along with the
information as available in or linked with Your Account (such as Your transaction history) to facilitate Your
use of Our Services and to enable You to complete Your transactions on the Platform expeditiously. In
particular, We (and Our Business Partners including third-party data processors, vendors and hosting partners
who may be engaged and authorized by Us and acting on Our behalf) may collect, store and process
Information Collected for the following reason(s):
5.1.1. to register the User, create Your Account and send verification message(s) or email(s);
5.1.2. to render the Services and provide loan facilities (and associated functionalities and transactions) for
User(s) through Our Business Partners;
5.1.3. to undertake billing and raise invoices for the Services;
5.1.4. to send confirmations and exchange communication regarding Services, in collaboration with Our
Business Partner, such as telephonically or through e-mail or SMS or or other messaging service as
may be applicable including sending any updates or changes thereto;
5.1.5. to allow Our customer service to contact You, if necessary;
5.1.6. to request for feedback or reviews of Our Platform and/or Services or any other improvements thereto;
5.1.7. to validate/authenticate Your Account and to prevent any misuse;
5.1.8. to analyze data about Our Users’ activity on Our Platform;
5.1.9. to help diagnose problems with Our data server, and to administer Our Platform.
5.1.10. for responding to the judicial process and providing information to law enforcement agencies or any
government agency in connection with a query/investigation on matters as permitted by law;
5.1.11. to allow third parties to contact with You in relation to Services availed/requested by You on Our
Platform (for the purposes defined in this Privacy Policy or the Terms) or through third party links;
5.1.12. to identify security breaches and attacks, investigating, preventing and taking action on illegal or
suspected fraud or money laundering activities and conducting forensic audits as part of internal or
external audit or investigation by Us or government agencies located within India or outside
jurisdictions;
85.1.13. for sharing, disclosing and transfer of data in case of any major event such as merger, acquisition,
sale or transfer of assets in case of any force majeure event to any third party with prior intimation to
You;
5.1.14. for data processing, statistical or risk analysis and for analytics and review for improvement of the
Services;
5.1.15. for designing and marketing Our Services and the Company’s business;
5.1.16. to resolve disputes; troubleshoot problems; help promote a safe service; collect payment; measure
consumer interest in Our products and services or detect and protect Us against error, fraud and other
criminal activity; enforce Our Terms and the Agreement; and as otherwise described to You at the
time of collection as part of the Agreement.
5.2. Further, We may use, store and process the Information Collected for the following reason(s):
5.2.1. for fulfillment of the Services, including to make the Services of this Platform customized; to provide
Services tailored to individual requirements; to understand Your needs and provide You with
improved Services;
5.2.2. to maintain any registered Accounts that You may hold with Us and to provide You with updates or
notifications of changes to Your Account;
5.2.3. for Our internal record keeping requirements including collection of anonymized details about visitors
to Our Platform to compile aggregate statistics or produce internal reports;
5.2.4. to communicate with You and to share with You additional and/ or upcoming information regarding
the Services offered by Us on the Platform;
5.2.5. to better understand how the Users access and use Our Services; and
5.2.6. for any purposes related to the above or where We have a legal right or duty to use, process or store
Your Personal Information (including for abuse, crime and fraud prevention and related purposes);
5.3. We may disclose Your Personal Information as part of any merger, sale of the Company assets or acquisition,
as well as in the event of insolvency, bankruptcy or receivership upon prior written intimation to You.
5.4. Our Platform may contain links to third party websites or applications. The User agrees and understands that
these website(s) and application(s) are not under Our control and subject to additional and separate terms
and policies. The User acknowledges and accepts that once the User leaves Our servers, use of any
information provided by the User will be governed by the privacy policy and terms of the operator of these
website(s) and application(s).
6. SHARING OF INFORMATION
6.1. Subject to the Privacy Policy, You acknowledge and accept that Your Information Collected shall be
disclose, transferred and shared with the parties mentioned below who are responsible for fulfilling Services
(and relative payments and functionalities) requested by Users on the Platform in accordance with the
Privacy Policy. You further acknowledge and accept that while making use of Our Platform with the
9Company, You authorize Us to share Your Information Collected with the said parties in the manner
described below.
6.2. We may share Your Personal Information (including Sensitive Personal Information) with Our Business
Partners for purpose(s) defined under this Privacy Policy in the course of Your transactions on the Platform.
Except for Our Business Partners, We do not disclose or transfer Your Personal Information to any third
parties without Your prior consent except in limited and specific circumstances where such disclosure is
mandatory, as elaborated herein.
6.3. Where relevant for fulfillment of Services, We may share Your Personal Information (including Sensitive
Personal Information) with Our Business Partners, who are contractually bound to safeguard the
confidentiality and security of such information in accordance with applicable laws and this Privacy Policy.
We may share Your Personal Information as well as Your non-personal information (such as Your User
Data) with Business Partners that We work with for facilitating the Services as well as other associated
business activities/facilities/transactions including not limited to billing, payments, communication,
consumer support, marketing, data and information storage, transmission, security, analytics, audit,
investigation, forensics, fraud detection, risk assessment in the manner permitted under law on a need-to
know basis.
6.4. We re-iterate that other than is specifically stated in this Privacy Policy, We will only share Your Personal
Information (including Sensitive Personal Information) in the event it is required to do so by applicable law,
rule, regulation, law enforcement agency, governmental official, legal authority or similar requirements
applicable to the Company or where Company, in its sole discretion, deems it necessary in order to protect
its rights or the rights of others, to prevent harm to persons or property, to fight fraud and credit risk, or to
enforce or apply the Privacy Policy and Agreement, as and when deemed necessary under applicable laws.
We may share Your Personal Information if required to do so by law or in the good faith belief that such
disclosure is reasonably necessary to respond to court orders, or for other legal process. We may share Your
Personal Information with government or judicial or other competent legal bodies (such as law enforcement
agencies) in the good faith belief that such disclosure is reasonably necessary to enforce Our Agreement,
respond to claims or orders or notices or other lawful requisitions or for other compliance with applicable
laws and regulations. Such transfer or disclosure shall be for lawful purposes and made subject to applicable
laws in India.
6.5. We do not share Your Personal Information (including Sensitive Personal Information) with Business
Partners for any other purposes except as may be necessary for the fulfillment of their part of Services or as
mentioned in this Privacy Policy. However, User accepts and acknowledges that the said parties use/process
Personal Information We share with them for their services as independent data controllers, and such
processing may also be subject to separate terms and privacy policies. If You choose to avail any loans from
or services offered by said parties, the services or facilities so availed will be governed by the terms and
conditions of the privacy policy of the respective party providing such services per the Agreement.
106.6. We disclose Your Personal Information (including Sensitive Personal Information) subject to lawful contract
and applicable statutory requirements such as for the purpose of or as part of any merger, sale of the
Company assets or acquisition, as well as in the event of insolvency, bankruptcy or receivership upon prior
written intimation to You.
6.7. In the interests of improving personalization and service efficiency, We may, under controlled and secure
circumstances, share Your Personal Information with select customer support and marketing Business
Partners. This will enable Us to provide You with information which might interest You in relation to the
Services; or help Us address Your questions and requests in relation to Your use of the Platform.
6.8. If the Company’s assets are acquired, Users should note that Our customer information (including Your
Personal Information) may also be transferred to the acquirer depending upon the nature of such acquisition
in accordance with this Privacy Policy. In relation, as part of business expansion/development/restructuring
or for any other reason whatsoever, if We decide to sell/transfer/assign Our business, any part thereof, then
as part of such restructuring exercise Our customer information (including the Personal Information
collected herein shall be transferred accordingly in accordance with this Privacy Policy.
6.9. We may use User’s Personal Information to display relevant advertisements on the Platform, based on Your
preferences, however, We do not sell User’s Personal Information to any advertisers or any third party. We
do not sell or rent individual customer names or other Personal Information of Users to third parties, save
and except sharing of such information with Business Partners.
6.10. We use non-identifiable Personal Information of Users in aggregate or anonymized form to build higher
quality, more useful online services on the Platform by performing statistical analysis of the collective
characteristics and behavior of Our customers and visitors, and by measuring demographics and interests
regarding specific areas of the Platform. We may provide anonymous statistical information based on this
data to current and potential Business Partners. Any Personal Information which We collect and which We
may use in an aggregated format is Our property. We may use it, in Our sole discretion and without any
compensation to You, for any legitimate purpose.
7. STORAGE AND SECURITY
7.1. Subject to the Privacy Policy, we retain and store certain Personal Information (excluding Sensitive Personal
Information) we collect from Users strictly as is necessary for the business purposes which are elaborated
herein. The security of Your Personal Information is important to Us. All Personal Information (excluding
Sensitive Personal Information) collected on Our Platform is securely transmitted to Our internal computer
servers and to the Bluehost India servers to ensure secure storage of data and is securely stored with Us and
our relevant Business Partner (subject to applicable services policies of such Business Partner). The database
is stored on servers secured behind a firewall; access to the servers is password-protected and is strictly
limited. We implement commercially reasonable physical, managerial, operational and technical security
measures to protect the loss, misuse and alteration of the Personal Information in Our possession. We take
necessary precautions to protect Your Personal Information both online and off-line and implement
11reasonable security practices and measures that are commensurate with respect to the information being
collected and the nature of Our business in accordance with legal and industry standards and the applicable
laws.
7.2. Although We make best possible efforts to store Your Personal Information in a secure operating
environment that is not open to the public, the User acknowledges and agrees that there is no such thing as
complete security, and We cannot guarantee safety or security of Your information as events beyond Our
control can also occur, both during transmission of Your information and once We receive it. If We become
aware that there has been any unintended disclosure of Your Personal Information in a manner not in
accordance with this Privacy Policy, We will use reasonable efforts to notify such User of the nature and
extent of such disclosure as soon as reasonably possible and as permitted by law. We encourage the User
to follow certain security measures on their part, including: if using a computer in a public location, to
always log out and close the website browser when You complete Your online session; keep Your Account
details and passwords private; frequently change Your password; and avoid using the same password for
multiple online accounts.
7.3. Tenure of Storage and Retention of Information Collected: We retain Your Information Collected for as
long as is reasonably necessary to fulfill the purposes listed in this Privacy Policy so as to provide You with
access to Our Services and Platform. You acknowledge, accept and understand that SWIPELOAN will
retain Your Personal Information (excluding Your Sensitive Personal Information) on its servers for as long
as is reasonably necessary for the purposes listed in this Privacy Policy. We do not store and retain Your
Sensitive Personal Information upon sharing the same with relevant Business Partners in accordance with
the Privacy Policy. However, in some circumstances, We may retain Your Personal Information (including
Your Sensitive Personal Information) for longer periods of time, for instance where We are required to do
so in accordance with any legal, regulatory, tax or accounting requirements.
7.4. The User acknowledges and understands that the third-party storage servers utilized by Us are subject to
additional and separate terms and policies of their operators which may be applicable to the User. You
acknowledge and agree that We may retain Your Personal Information in the manner mentioned in this
Privacy Policy for the purpose of the Services and in accordance with any legal, regulatory, tax or
accounting requirements.
8. CONSENT AND WITHDRAWAL OF PERMISSIONS
8.1. Users are encouraged to communicate any grievances regarding User’s Personal Information (including
Sensitive Personal Information to Our Grievance Officer in writing by using the applicable contact details
set out at clause 10 of this Privacy Policy. In case the User opts to decline to provide consent or withdraw
any consent granted to Us in respect of collection or processing of the User’s Personal Information
(including Sensitive Personal Information) or request deletion of any of the Information Collected, the User
acknowledges and agrees that such action may interfere with or render it impossible for Us to continue
offering You the Services (or to offer You any additional Services) and We may be forced to limit, suspend
or terminate Your access to the Platform and/or the Services.
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8.2. User hereby agrees and acknowledges that We shall not be held liable in any manner whatsoever if We are
unable to perform Our Services or if there is a deficiency in the Services provided by Us due to any
Information Collected which You provide to Us which is incorrect (in whole or in part) or due to any
withdrawal of consent. User acknowledges and agrees to indemnify and hold Us and/or Our employees,
consultants, directors, representatives and/or associates, etc. harmless from any complaints, legal
proceedings or claims filed or initiated by any third party against Us due to any breach by the User of the
terms of this Privacy Policy.
8.3. We provide Users with the opportunity to opt-out of receiving non-essential (promotional, marketing
related) communications from Us (on behalf of Our Business Partners, and from Us in general) after setting
up an account by sending an email to the following email address: info@swipeloan.in. To the extent We use
Your Personal Information to market to You, We will provide You the ability to opt-out of such uses. In
case, You choose to do so then Your access to the Platform may be limited, or We might not be able to
provide the Services to You.
8.4. We re-iterate that in case You have any concerns in the collection and processing of Your Personal
Information or any relative consent or permission You have granted Us in this regard, please reach out to
Our Grievance Officer in the manner provided in this Privacy Policy.
9. CHANGES TO PRIVACY POLICY
9.1. You acknowledge and accept that the Company may update this Privacy Policy at any time, with or without
advance notice. In the event there are changes in the way Company treats User’s Personal Information
(including Sensitive Personal Information) or in the terms of Privacy Policy itself, Company will display a
notice on the Platform or send Users an email, as provided for above, so that You may review the changed
terms prior to continuing to use the Services.
9.2. If You object to any of the changes to Our Privacy Policy, and You no longer wish to avail the services, You
may contact Us at info@swipeloan.in to deactivate Your account or may contact in the manner specified in
clause 10 herein for any other grievances or issues related to the collection of Your Personal Information
under this Privacy Policy. Unless stated otherwise, Our current Privacy Policy applies to all information that
the Company has about You and is associated to Your Account with Us. If a User uses the Platform, after a
notice of changes published on the Platform, such User hereby consents to the changed terms.
10.
GRIEVANCE REDRESSAL
In case You have complaints, queries or concerns pertaining to the Privacy Policy or our use of Your
Personal Information, (including Sensitive Personal Information), You can direct any questions or
complaints to Us by contacting Our designated grievance officer (“Grievance Officer”) in writing via e
mail or post using the contact details mentioned herein below. Any communication pertaining to any
discrepancies, points of concern or grievances as regards the Privacy Policy and any complaints, abuse or concerns with regards to content and/or breach of the terms herein must be immediately informed to the
Grievance Officer (using the contact information mentioned below) in writing. The Company shall not be
responsible in the event that You address any communication to any non-designated person in this regard.
Name: Mr. Prashant Bhosale
Office Address: Office No-219, Gera’s Imperium
Rise, Hinjawadi, Phase-2, Pune -411057.
Email Address: grievance@swipeloan.in
You are expected to provide the Grievance Officer with all necessary information and/or documents to
enable the Grievance Officer to resolve the issue. We shall not be responsible in the event of Your failure to
provide Us with such reasonable information and documents as We may necessarily require to address Your
grievance. The grievances received under this paragraph shall be dealt with in adherence to the timelines
specified under the Information Technology Act, 2000 and the applicable rules notified thereunder.
While We will investigate and attempt to resolve any queries regarding the use or disclosure of Your
Personal Information as soon as possible, occasionally it may take Us longer to respond to You, if Your
request is particularly complex or You have made a number of requests. In this case, We will notify You
and keep You updated.
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