Privacy Policy

1. Purpose

This Policy sets out the manner in which we collect, use, process, disclose, store, and protect your personal data, in accordance with the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, the Digital Personal Data Protection Act, 2023 ("DPDP Act"), and other applicable data protection laws of India.

2. Applicability

This Policy applies to all individuals who visit the Platform, submit a loan or financial-product enquiry, register an account, or otherwise engage with us. It describes the personal data we collect, how we process and share it, including with our Lending Partners, banks, non-banking financial companies ("NBFCs"), and other financial service providers, and your rights in respect of such data.

3. Personal Data We May Process

3.1 Information You Provide to Us

• Full name, email address, mobile number, and residential or business address.
• Date of birth, employment/income details, and other information submitted in connection with a loan enquiry or eligibility check.
• Details submitted through enquiry, callback, registration, or lead-capture forms on the Platform.
• Information shared while communicating with our sales, support, or collections/recovery teams, including over calls, WhatsApp, email, or chat.
• Any documents, such as identity or income proof, voluntarily uploaded for the purpose of a loan enquiry, subject to Clause 3.3 below.
• Feedback, survey responses, and correspondence with the Company.

3.2 Information Collected Automatically

• Device information such as IP address, browser type, operating system, and device identifiers.
• Log data including pages visited, features used, time and duration of visit, and referring/exit pages.
• Location information, where enabled on your device.
• Cookies and similar tracking technologies, as described in Clause 7 below.

3.3 Information Received from Third Parties

• Confirmation and supplementary information from Lending Partners, credit bureaus, or verification/aggregator services engaged to validate the details you have submitted, such as confirming your name, address, or contact details match records held by such third parties.
• Information received from our business partners, affiliate marketing partners, and referral sources through whom you may have expressed interest in our services.
• Publicly available information used for verification purposes, to the extent permitted by law.

We do not ourselves collect or store sensitive financial identifiers such as bank account numbers, card numbers, or government identification numbers beyond what is strictly necessary to route your enquiry to a Lending Partner, and any such information is handled in accordance with Clause 8 (Security Measures) below.

4. How We Collect Personal Data

4.1 Information You Provide

This includes information you submit while filling an enquiry or loan-comparison form, registering on the Platform, subscribing to updates, or voluntarily providing feedback.

4.2 Information from Linked Platforms

Where the Platform allows you to connect via a social media or third-party account, we may receive information permitted by your privacy settings on such platform. You may withdraw this access at any time through your account settings on the relevant third-party platform.

4.3 Information Collected Automatically

We collect technical and usage information to operate and improve the Platform, such as your IP address, browser type and language, access times, referring/exit URLs, and pages viewed. This aggregated information helps us improve the Platform and is not used to track the activity of a specific identifiable visitor beyond what is necessary for security and functionality.

4.4 Automated Decision-Making

Unless otherwise required or permitted under applicable law, we do not use your personal data for fully automated decision-making that produces legal or similarly significant effects concerning you, such as an automatic loan rejection with no human review. Any eligibility screening carried out on the Platform is indicative only and does not bind any Lending Partner's final credit decision.

5. Legal Basis for Processing

We process your personal data on the basis of your consent, the performance of a contract with you, our legitimate interests, or to comply with a legal obligation. Our primary purposes for processing personal data are to generate and route verified loan enquiries to Lending Partners, to operate and improve the Platform, and for related marketing and service-improvement activities.

6. How We Use Your Personal Data

The table below summarises the main purposes for which we use your personal data, the categories of data involved, and the basis on which we rely to process it.

In summary, we use your personal data to provide and monitor the Platform and our services; communicate with you about your enquiry and related offers, including via email, SMS, WhatsApp, and RCS channels; personalise and improve your experience on the Platform; conduct market research to enhance our offerings; and comply with applicable law and protect our legal rights.

7. Cookies

Our Platform uses cookies and similar tracking technologies, small text files stored on your device, to operate certain features, remember preferences, and understand usage patterns. You may accept or reject cookies through your browser settings; disabling cookies may, however, affect the functionality of certain features on the Platform.

8. Sharing and Transfer of Personal Data

We share your personal data with our Lending Partners so that they may evaluate and respond to your loan enquiry, and with vendors and service providers who support our operations, such as hosting, analytics, verification, and communication service providers, subject to confidentiality obligations. Where any such transfer takes place outside India, we take reasonable steps to ensure the recipient affords an adequate level of protection to your personal data, consistent with the DPDP Act and any rules notified thereunder. By using the Platform, you consent to such sharing and transfer of your personal data as described in this Policy.

9. Data Retention

We retain personal data for as long as necessary to fulfil the purposes described in this Policy, or as required to comply with legal, regulatory, accounting, or dispute-resolution obligations. Once the purpose of collection is fulfilled and no further retention obligation applies, we take reasonable steps to delete or anonymise such data.

10. Children's Privacy

The Platform is not intended for individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that personal data has been collected from a minor without appropriate consent, we will take steps to delete such data as soon as reasonably possible.

11. Security Measures

We implement reasonable physical, electronic, procedural, and managerial safeguards designed to protect your personal data against loss, unauthorised access, misuse, or alteration, and we require third parties processing personal data on our behalf to maintain comparable safeguards. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

12. Changes to this Policy

We may update or amend this Policy from time to time. Material changes will be notified through a prominent notice on the Platform, and/or by email, along with an updated "Effective Date". Your continued use of the Platform after such changes take effect constitutes acknowledgment of, and consent to, the revised Policy. We encourage you to review this Policy periodically.

13. Your Rights

Subject to applicable law, including the DPDP Act, you have the following rights in relation to your personal data:

• Right to Access - to confirm whether we process your personal data, and to obtain a copy of it.
• Right to Correction and Updation - to have inaccurate or incomplete personal data corrected.
• Right to Erasure - to request deletion of your personal data, subject to our legal and legitimate business retention requirements.
• Right to Withdraw Consent - to withdraw consent previously given, without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to Object - including to object to your data being used for marketing communications.
• Right to Grievance Redressal - to raise a grievance with us in the manner set out in Clause 14 below, and, where applicable, to escalate the grievance to the Data Protection Board of India or other competent authority.

14. Grievance Redressal

If you have any questions, concerns, or grievances regarding this Policy or the processing of your personal data, you may contact us at:

15. Governing Law and Jurisdiction

This Policy shall be governed by and construed in accordance with the laws of India. Any disputes arising out of or in connection with this Policy shall be subject to the exclusive jurisdiction of the competent courts at Delhi.

16. Contact Us

Apexon Consultant & Engineering Private Limited ("Apex On Leads")