Policy | MyShubhLife

THIS WEBSITE WWW.MYSHUBHLIFE.COM AND APPLICATION “MYSHUBHLIFE” AND OTHER RELATED INTERNET BASED APPLICATIONS (COLLECTIVELY REFERRED TO AS APP) OWNED AND OPERATED BY DATASIGNS TECHNOLOGIES PRIVATE LIMITED, A COMPANY INCORPORATED UNDER THE LAWS OF REPUBLIC OF INDIA HAVING ITS REGISTERED OFFICE NOVA MILLER, 333 THIMMIAH ROAD, VASANTH NAGAR BANGALORE - 560052 (HEREINAFTER REFERRED TO AS “WE”, OR “US” OR OUR OR “DTPL”) AND “YOU” AND “YOUR” SHALL MEAN YOU AS A USER OF THE APP (“USER”), WHETHER REGISTERED OR NOT.

THIS PRIVACY POLICY GIVES YOU DETAILS ABOUT OUR DATA COLLECTION METHODS AND USAGE. YOU ARE ADVISED TO READ THIS PRIVACY POLICY ALONG WITH THE TERMS OF USE AND OTHER INFORMATION IN THE WEBSITE/APPLICATIONS.

USERS PLEASE TAKE NOTE THAT ANY STATEMENTS MADE ON DTPL WEBSITE/APPLICATIONS SHALL NOT BE CONSTRUED AS AN OFFER OR PROMISES FOR GRANT OF ANY FINANCIAL SERVICES.

THIS PRIVACY POLICY IS PUBLISHED IN COMPLIANCE OF THE INFORMATION TECHNOLOGY ACT, 2000, THE INFORMATION TECHNOLOGY (REASONABLE SECURITY PRACTICES AND PROCEDURES AND SENSITIVE PERSONAL INFORMATION) RULES, 2011, GUIDELINES DATED 02.09.2022 ON DIGITAL LENDING BY RESERVE BANK OF INDIA (RBI) AND OTHER APPLICABLE LAW AS AMENDED FROM TIME TO TIME.

INFORMATION COLLECTED BY DTPL
1. Certain mandatory information will be collected at the time of registration on the App which is required to enable the User to login to the App and for us to: (i) verify the User’s identity; (ii) determine the User’s eligibility for taking loans or other financial products using, inter alia, our proprietary technology and such additional rules that may be determined by: (a) us; (b) our banking partners; or (c) both (a) and (b); and (iii) safeguard against illegal activities like fraud, cheating, misappropriation, etc.
2. Personal Information- For providing Services we require certain information with your consent such as name, date of birth, mobile number, e-mail address, residential address, current address, company name, PAN, salary, Selfie, KYC documents etc. and certain information about your personal identity such as gender, age, etc. Further, we also collect and store your usernames, passwords, email addresses and other security related information that you use for our sites in relation to our Services.
3. In order to use the facilities and Services available on the App, the User may be required, from time to time, at the request of DTPL to provide certain additional personal information after registration on the App including credit bureau data, Bank Statement, ITR etc if required, which information shall be collected only upon receiving the User’s explicit consent.
4. We may also automatically receive and collect certain anonymous information in standard usage logs through the web server, including mobile-identification information obtained from the equivalent of “cookies” sent to the App, including mobile network information, standard web log information, traffic to and from our App, tracking inside the App and any other available information, from:
  1. an IP address, assigned to the device used by the User;
  2. the domain server through which the User accesses the App and the functions and features therein; and
  3. the type of device used by the User (“Device”)
5. The User may choose to provide us with access to certain personal information stored by third parties like social networking sites (e.g., Facebook and Twitter). We will have access to such information to the extent allowed by the User’s privacy settings on that site and the User’s specific authorization. In the event the User associates a User account managed by us with an account maintained with any third party to enable us to access certain information maintained in such third party managed accounts, the User agrees that we may collect, store and use such information in accordance with this Privacy Policy.
6. SMS- After obtaining the User’s specific consent to allow the App to access the User’s SMS, we may collect relevant information from Transactional text messages from Business received by the Users from providers of services and/or products (including but not limited to retail outlets, financial institutions, mobile carriers and utility companies), that will enable us to provide better access to various financial services and products to the Users. We only access business messages that originate from 6-digit alphanumeric senders. This access will only be taken if it is allowed under statutory and regulatory guidelines for that particular product which the user has applied for. We do not share this data with any third party. DTPL will not collect or store any personal SMS from Inbox. This access is required for the purpose of income verification, credit worthiness and profile authentication in order to determine eligibility for financial products.
7. Location- In order to enhance our ability to provide valuable Services and experiences to the User, we may: (i) with explicit consent receive, collect and analyze your location information which may be accessed through a variety of methods including, inter alia, GPS, IP address, and cell tower location; and (ii) collect information pertaining to your Device and your usage thereof, including, inter alia, the names of the other applications on your mobile Device and how you use them, information about your Device, and information about your use of features or functions on your Device. We do not share this data with any third party.
8. Installed apps- We collect a list of the installed applications’ metadata information which includes the application name, package name, installed time, updated time, version name and version code of each installed application on your device to assess your creditworthiness and enrich your profile with pre- approved customized Financial Products. This also includes having access and permission to send you messages and notifications via your social media and instant messaging applications. You will not be able to use the App if you disable this access. We do not share this data with any third party.
9. Camera & File Chooser- We may require camera access to capture images & upload to our servers, particularly selfie and/or the required KYC documents as per our lending partners and in accordance with applicable laws. These documents may also be collected via File Chooser dialog with user consent. We will transfer such information to our lending partners and not store any such information beyond the required duration.
10. Microphone, Contacts, Call logs- We do NOT access, collect or upload Contacts, Call logs & any data from Microphone.
11. We may also collect information from third party in order to verify the details provided to us or for having more details about the users with user’s explicit consent such as for employment verification we may verify with your HR etc.
12. We may also collect Non-personal data available in public platform to verify the details.
13. Phone- We collects and monitors information about your device including the phone model, the operating systems, IMEI, serial number, battery information, and mobile network to uniquely identify the user and protect against unauthorized access to your account.
METHOD AND MANNER OF USE OF INFORMATION:
1. When the User registers with the App and apply for credit or any other Financial product, we will use the information supplied by the User to access credit information from credit bureaus, with user consent only for credit product, and for identity verification services for every financial product to facilitate banks and other financial institutions for loan and or other financial product to evaluate the User’s request in the context of the User’s complete financial situation
2. The intended purpose of collecting information provided by you is to:
  1. Establish identity and verify the same;
  2. Provide personalized features;
  3. Aiding Financial Service organization to provide better services
  4. Facilitating collection activities as needed;
  5. Maintaining regular communications with the User concerning transactions that the User initiates, such as requesting information or assistance, submitting a loan request or other Financial product and service, making payment etc;
  6. Modifying the App from time to time to cater to the User’s interest;
  7. Delivering any administrative notices, alerts, advice, notification and communication relevant to your use of any facilities on the App through Whatsapp, SMS, facebook and other medium;
  8. Marketing research, project planning, troubleshooting problems, detecting/protecting against error, fraud or other criminal activity;
  9. For undertaking KYC authentication and other identification process for different financial products;
  10. Resolving disputes in relation to the facilities if any;
  11. Providing the app and the functions and features therein efficiently;
  12. Preserve history as governed by existing law or policy;
  13. Generating and maintaining User profiles on the App.
3. You acknowledge that if we determine that any information you have provided or uploaded violates the terms of this Privacy Policy, we have the right, in our absolute discretion, to delete or destroy such information without incurring any liability to you.
4. You acknowledge that you are licensing us to use, modify, display, distribute and create new material from the information you provide through the App to render certain Services on the App. By providing such information, you automatically agree, or promise that the owner of such information has expressly agreed to allow or license, as the case may be, us to use the information in the manner set out in this Privacy Policy, without the payment of any fees. We may, to the extent permitted by law, also use, license, reproduce, distribute disclose, and aggregate, non-personally identifiable information that is derived through your use of the App and you hereby provide consent for the same.
SHARING OF INFORMATION WITH THIRD PARTY
1. Subject to the restriction mentioned in clause 1 above, we will not use User information for any purpose other than in connection with the App and for the purpose it collected. You understand that in order to provide the Services, we will share the User information with third parties with your explicit consent who will be evaluate for providing financial products availed or Parties through the App or otherwise and you agree to such User information being shared. DTPL will not rent, sell or share User information and will not disclose any of the User’s personally identifiable information to third parties or affiliates, unless:
  1. It is in connection with disclosure to financial institutions and banks or registered entity who will provide the service, in which case, the user hereby gives his explicit permission;
  2. It is in connection with the Services being rendered through the App;
  3. 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 person, violations of our Terms of Use, or as defence against legal claims;
  4. It is a case of special circumstances such as compliance with court orders, requests/order, notices from legal authorities or law enforcement agencies compel us to make such disclosure;
  5. It forms part of the information we share with advertisers on an aggregate basis;
  6. It personalization, analysis and for offering new products/services;
  7. It is required under an arrangement between us and the third party for product enhancement, analysis, risk and security purposes, communication purpose etc.;
  8. If required for any statutory and regulatory purpose;
  9. It is required for collection purpose;
  10. such other purpose for which user shall give explicit consent to share
2. If all or some of the business, stock or assets of DTPL are acquired or merged with another business entity, we will share all or some of your information with the acquiring / merged entity to continue to provide the Services to you.
3. If you decline to submit information which may require mandatory to us for providing the services applied for, then we may unfortunately not be in a position to provide the Services to you.
4. The limited information of the users shall only be shared which is required for the above mentioned purpose.
5. DTPL will share only need based data with third party to provide the relevant service as requested by you with your explicit consent.
SERVICE PROVIDERS
1. We may employ third-party service providers and individuals due to the following reasons:
  1. To facilitate our Service; or
  2. To provide the Service on our behalf; or
  3. To perform Service-related services; or
  4. To assist us in analyzing how our Services are used.
2. You acknowledge that the third-party service provider/agent/agencies will have access to your personal information on a need to know basis to assist us in rendering Services, and the service providers are restricted from using the same for any other reason. The third-party service providers are obligated not to disclose or use the information for any other purpose.
DATA RETENTION:
1. We take reasonable steps to ensure that information about you is available only for so long as is necessary for the purpose for which it is processed, or longer if required under any contract, by applicable law, or for statistical purposes, subject to appropriate safeguards subject to the maximum of 30 years. Limited Data which is required for the servicing service availed will only be stored or where required as per any applicable laws. Data stored will only use for mentioned purpose and will be restricted for usage only with the explicit consent of the Borrowers obtained from time to time.
  
  User understand that Banks/Financials entity who has evaluated the customer for credit or any entity who has provided their service through DTPL may store all the data collected as per their statutory and regulatory requirement. DTPL shall purge from the system the data taken exclusively for credit facility.
  
  Except as permitted by applicable law, the information / data stored, retained, processed and transmitted pursuant to this Privacy Policy shall reside at a data storage centre within the geographical territories of India.
INFORMATION SECURITY AND STANDARDS FOR HANDLING SECURITY BREACH
1. The information provided by the User is stored in access controlled facilities with restricted access. User Information transmitted over the internet is protected through the use of encryption, using the Secure Socket Layer (SSL) or equivalent protocols.
2. If a password is used to help protect User accounts and account information, it is the responsibility of the User to keep the password confidential. You have to ensure that you always log out, before sharing the device with a third party and it is advised that the User utilizes a Service to protect access to the User’s Device.
3. We shall use generally accepted industry standards to protect the User information submitted to us, both during transmission and upon receipt. However, please be advised that, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, even though we strive to use commercially acceptable means to protect User information, we cannot guarantee its absolute security and your use of the App is at your sole risk and discretion. We also cannot warrant that such User information may not be misused in the event our safeguards and protocols are breached by a malicious third-party. Further, we are not liable to, nor can we fully control the actions of other users with whom you may choose to share your information.
4. The collection, usage, and sharing of User information by us shall be in compliance with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and other applicable laws. Data Security is our priority and we shall take all steps to protect and secure customer’s personal information in terms of collection, process, storage etc.
5. If any security breach comes to our knowledge, then we may take all steps required to protect misuse of such information:
  1. Secure areas potentially related to the breach and mobilize IT team right away to prevent additional data loss
  2. Switch off the servers and change the access code to prevent additional data loss
  3. Fix vulnerabilities
  4. Identify the sensitivity of data breached and possible impact
  5. Notify the appropriate regulatory/Statutory Bodies and affected parties
  6. Take the steps to improve the system security
PROCEDURE FOR REMOVING USER DATA OR WITHDRAW CONSENT
1. If and when a User is desirous of having his/her name and other details removed from the records of DTPL, immediately upon receiving the User’s written request to that effect we shall, subject to the terms hereof, remove and/delete all such information. User may write at support@myshubhlife.com for deletion/Withdrawal of any data collected and stored or any consent given including consent for sharing the data with third party. We reserve the right to restrict or discontinue the service basis on the users request for data deletion that is required to perform the services.
  
  The User have the option, at any time while availing our Services or otherwise to give or deny consent for use of specific data, restrict disclosure to third parties, data retention, revoke consent already granted to collect personal data and if required, make the app delete/ forget the data. In case of withdrawal/deny of your consent, we reserve the option not to provide the Services for which such information was sought. In case the Services are already availed and then you raise a request to withdraw consent, then we have the right to retain all the necessary data required to carry out our operations. The user can exercise the same by mailing us at support@myshubhlife.com.
2. If the User no longer wishes to receive notifications about our Services, The User may change his/her notification preferences by contacting us at support@myshubhlife.com. We reserve the right to close the User account or restrict the services if the User opts out of receiving certain crucial notices that are required to perform the Services through the App.
3. Notwithstanding the foregoing, DTPL may retain information of the User if mandated under applicable law, even after receiving the User’s written request to remove/delete all such information.
PROCEDURE FOR CORRECTING INACCURACIES IN THE INFORMATION
1. The User may correct or update any information online. In the event of loss of access details, the User may retrieve the same or receive new access details by sending an e-mail to: support@myshubhlife.com/grievance@myshubhlife.com.
PRIVACY POLICY UPDATES
1. We reserve the right to change or update this Privacy Policy at any time. Such changes shall be effective immediately upon posting on this App. Your access and use of the App following any such change constitutes your agreement to follow and be bound by these Privacy Policy, as updated or modified. For this reason, we encourage you to review this Privacy Policy each time you access and use the App.
GRIEVANCE OFFICER
1. In case of any grievance, you may contact the grievance officer Mr. Rahul Sekar on Ph. No. +91 9019900199 or email - support@myshubhlife.com / grievance@myshubhlife.com
DISPUTE RESOLUTION
1. In the event of any dispute, difference or claim arising out of this Privacy Policy the same shall be settled in accordance with the laws of India through regular judicial process and the courts of Bangalore, India shall have exclusive jurisdiction.
COOKIES
1. When You visit the App, one or more cookies will be sent to the computer/smartphone or other devices being used by you. The cookies are either used to improve the quality of the App or for storing your preferences as a user, improving search results and tracking user trends. You have the option of disabling cookies via your browser preferences. However, if you disable cookies on your browser, some parts of the App may not function effectively.
DATA DESTRUCTION PROTOCOLS
1. All restricted data files (e.g., all copies of the original restricted data and of all files derived in whole or in part from the restricted data) or the data whose storage is no longer required must be destroyed as per the process as applicable in a best possible way. There are multiple approaches that can be taken to make such files inaccessible such as Physical destruction of the device(s) (e.g., CDs, DVDs, tapes, diskettes) on which the restricted data files were stored, Secure erasure of storage media followed by reformatting, Secure deletion of individual folders and/or files.

Privacy Policy