PRIVACY POLICY

1. Introduction

This Privacy & Security Policy explains how we safeguard personal information provided through our websites, such as www.plebgraph.com, and our Android app, as well as how we utilize that information in connection with the services offered through the Site (the "Service").

For the purposes of this Policy, "Personal Information" refers to information that can identify you, such as your name, address, phone number, or email address. By providing your number at www.plebgraph.com, you authorize Plebgraph and its representatives to contact you, offering our services for the product you have selected, providing product information, and offering promotional offers available on the website.

Regardless of whether you have registered under the DND or DNC service, you are still granting us, our representatives, and our partners permission to communicate with you for the aforementioned purposes. There is no requirement for a DNC check for the number you provide when using Plebgraph services.

Our Privacy Policy undergoes regular reviews to ensure that we continue to protect your privacy interests. www.plebgraph.com adheres to stringent privacy and security standards to safeguard your personal information. We consistently reassess our policies and adjust them as needed to address new challenges.

To register with us, you must be 18 years of age or older and a resident of India. Minors are strictly prohibited from using the service.

2. How Plebgraph Collects Information ?

2.1 Information Provided by You to Plebgraph

If you intend to open a loan account with Plebgraph, you will be required to provide details such as your name, email address, mailing address, mobile number, PAN number, employment and income details, and other necessary information to assess your creditworthiness. Wherever possible, we indicate mandatory and optional fields.

You always have the option to refrain from providing certain information by choosing not to use a particular service or feature on the Platform. You will be provided with the option to give or deny consent for the use of specific data, restrict disclosure to third parties, control data retention, revoke previously granted consent to collect personal data, and, if necessary, request the deletion of data from the app.

We also collect user account data, including email addresses and user public profile information like names and photos, depending on the social media or networking platform used to log into an app, such as Google or Facebook.

In order to provide your bank statements or pay-slips electronically or physically with your loan application, you must provide your third-party account credentials ("Account Credentials") to allow www.plebgraph.com to retrieve your account data ("Account Information") from those financial institutions. Your Account Credentials are used solely for the purpose of retrieving your bank statements and pay-slips and are not stored in our system.

No biometric data is stored or collected in the systems associated with the DLA of REs (Regulated Entities) or their LSPs (Lending Service Providers), unless allowed under existing statutory guidelines. Our system complies with various technology standards and requirements on cybersecurity stipulated by RBI and other relevant agencies, or as specified from time to time, for conducting digital lending.

The Platform does not access mobile phone resources such as files, media, contact lists, call logs, telephony functions, etc.

Access to your Registration Information, Account Information, and any other Personal Information you provide is strictly confidential and used only in accordance with specific internal procedures and safeguards governing access, for the purpose of operating, developing, or improving the Service.

We may also use third-party service providers to assist us in providing the Service to you, such as sending email messages or SMS on our behalf or hosting and operating specific features or functionalities of the Service. We require these third parties to maintain the confidentiality of the information we provide to them.

All telephonic conversations are recorded for training and monitoring purposes. Such recordings may also be used to help us combat fraud.

To provide seamless approval and determine the instant creditworthiness of customers, we explicitly request certain permissions after users complete the signup process:

2.2 Information Collected by Plebgraph from Your Activities

Your information is collected when you visit the Plebgraph website or mobile app using your phone or computer. This information may include your IP address, contact details, device information, including but not limited to identifiers, names, types, operating systems, and location. We do not access your location or restricted data in the background for any marketing purposes. However, we may access data in the foreground with continued usage for tracking purposes and preventing fraud.

2.3 Cookies

If enabled, we may place cookies on your device that store small amounts of data about your visit to any of the pages on this website. Cookies can identify the pages being viewed, which can assist us in tracking which features appeal most to you and what content you may have viewed during past visits.

These technologies are used for analyzing trends, administering the site, tracking users' movements around the site, and gathering demographic information about our user base as a whole. Third-party vendors, including www.google.com ("Google"), may use cookies to serve ads based on your visits to this Website. You may visit the third-party website and choose to opt out of the use of cookies for interest-based advertising if the third party offers such an option.

We use cookies on our website to personalize our service to you. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited. You may refuse to accept cookies by activating the setting on your browser that allows you to reject cookies. Unless you have adjusted your browser setting to reject cookies, our system will issue cookies when you log on to the website.

3. How Plebgraph Protects Your Personal Details

3.1 Keeping Your Data Secure

We adhere to generally accepted standards for safeguarding the personal information you provide to us. We employ secure cryptographic techniques over HTTPS APIs to protect your personal data during transmission and upon receipt. We have implemented reasonable safeguards to ensure data security. However, it's important to note that no method of transmission over the Internet or electronic storage is 100% secure. Therefore, we cannot guarantee absolute security.

To maintain the security of your online session and protect www.plebgraph.com accounts and systems from unauthorized access, we utilize a combination of firewalls, encryption techniques, authentication procedures, and other security measures.

We store your information on servers located in India, and we have implemented physical and logical protections to prevent general employee access to our databases. Additionally, we encrypt your Service password in a way that makes it unrecoverable, even by us. All backup drives and tapes are also encrypted. Our employees are prohibited from placing sensitive content on unsecured machines, ensuring the security of your data.

3.2 Encryption and Secure Communication

All communications containing personal information between your computer, tablet, mobile devices, and www.plebgraph.com are encrypted. This encryption ensures that client and server applications communicate in a manner designed to prevent eavesdropping, tampering, and message forgery.

3.3 Confidentiality of Login ID and Password

You are responsible for maintaining the security of your Login ID and Password and must not share these credentials with any third party. If you suspect that your credentials have been stolen or compromised, you must immediately contact us at www.plebgraph.com.

Please note that we are not responsible if someone else accesses your account using Registration Information obtained from you or due to a violation of this Privacy and Security Policy or the Terms of Use (ToU).

4. How Plebgraph Utilizes Your Information

The purpose of collecting information provided by you is as follows:

1. Establish identity and verify it, with or without the assistance of third parties.
2. Complete onboarding and KYC requirements for third-party lending partners.
3. Monitor, improve, and administer our Platform.
4. Provide our services, including performing credit profiling to facilitate loans for you.
5. Design and offer customized products and services in collaboration with our third-party financial partners.
6. Analyze how the Platform is used, diagnose service or technical problems, and maintain security.
7. Send communications, notifications, and information related to the products or services you have requested, as well as process queries and applications made on the Platform.
8. Manage our relationship with you and inform you about other products or services that may be of interest.
9. Conduct data analysis to enhance the Services and Products provided to users.
10. Use user information to comply with country laws and regulations.
11. Conduct KYC for our third-party lending partners based on the information shared by users.
12. Use user information in other ways permitted by law to enable you to access financial services from our lending partners.

We will use and retain this information for the necessary periods to provide you with Services on the Platform, comply with our legal obligations, resolve disputes, and enforce our agreements.

5. When You Share Information with Plebgraph

You can review and edit your personal information at any time by logging into your account on the Website or by contacting the Plebgraph support team. If you choose to close your account, your personally identifiable information will no longer be used by us for any further purposes, nor will it be sold or shared with third parties, except as necessary to prevent fraud, assist law enforcement, comply with legal requirements, or in accordance with this Privacy Policy.

All other information shall be treated as non-confidential and non-proprietary. Plebgraph is under no obligation regarding such information and is free to reproduce, use, disclose, and distribute this information without limitation. Additionally, Plebgraph is free to use any ideas, concepts, know-how, or techniques contained in such information for any purpose, including developing or marketing services incorporating this information.

There is no legal obligation to delete the data from the server when you close your account or stop using our services. The data will be securely retained on our server and will serve the following purposes:

1. To comply with legal duties and requirements, whether statutory or regulatory.
2. To prevent liability through "spoliation," the improper destruction or alteration of documents in a litigation situation.
3. To support or oppose a position in an investigation or litigation.
4. To protect against unnecessary expense and time during discovery.
5. To maintain control over discovery and e-discovery.
6. To keep documents confidential and prevent leakage to attackers or competitors.
7. To enforce our Terms and Conditions.

   While we do not retain your personal data for longer than necessary for the intended purpose, for any other information, we may entertain your request for deletion. However, please note that you may not be able to use our Services at all after such deletion. We will share your information with registered third parties, including our regulated financial partners, for the provision of services on the Website/App. Your information will be shared with third parties only in the following manners:

8. Disclosure to financial service providers, banks, or NBFCs, and our third-party partners to facilitate loans, facilities, lines of credit, or product purchases.
9. Sharing with third-party partners to conduct data analysis for better service provision on our Platform.
10. Disclosure of information without prior notice if required to comply with legal obligations, government or statutory authority orders, enforce our terms of use, or during corporate divestitures, mergers, or to protect the rights, property, or safety of Us, Our users, or others.
11. Sharing of data/information provided by a User with other technology partners to track interactions with the Platform on Our behalf.
12. Sharing of information with another business entity in the event of a merger, acquisition, reorganization, amalgamation, or business restructuring. Such entities will be bound by this Policy with respect to your information.
13. Disclosure of information to third-party technology and credit partners for credit checks and analysis, such as Credit Bureaus or third-party data source providers.
14. Sharing of your information under a confidentiality agreement with third parties, restricting the use of said information to the purposes detailed herein.
15. Consent to share/disclose your Personal Information to governmental authorities, quasi-governmental authorities, judicial authorities, and quasi-judicial authorities, in accordance with applicable laws of India.
16. Disclosure of your KYC journey or related data to relevant regulatory authorities as part of our statutory audit process. Please note that your Aadhaar number will never be disclosed.

In case we use or disclose your information for any purpose not specified above, we will obtain your explicit consent.

6. Security Precautions

The Platform is dedicated to safeguarding your information and ensuring its accuracy, as verified by you. We employ a combination of reasonable physical, administrative, and technical safeguards to protect your information against unauthorized access, usage, and disclosure. As an illustration, all information is encrypted when transmitted over the internet.

Furthermore, we mandate that our registered third-party service providers safeguard such information against unauthorized access, usage, and disclosure. Our Platform incorporates rigorous security measures to shield against loss, misuse, and unauthorized alteration of controlled information.

Our commitment to ensuring the security of the information you provide is unwavering. We utilize Secure Sockets Layers (SSL)-based encryption for information transmission, aligning with the current encryption requirements mandated by Indian law. We integrate security measures at multiple stages within our products, leveraging state-of-the-art technology to maintain robust security protocols.

Our data and privacy security design enables us to safeguard our systems, addressing issues ranging from basic vulnerabilities to intricate attacks. Our Platform employs stringent security measures to safeguard information from loss, misuse, or alteration, including:

1. Encryption for data privacy during transmission.
2. Security features such as OTP verification to enhance account protection.
3. Regular review of information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems.
4. Restricting access to personal information to employees, contractors, and agents who require it to process the information. Those with access are bound by strict contractual confidentiality obligations.
5. Compliance with regulations and applicable laws.
6. Periodic review of this Privacy Policy to ensure alignment with data processing practices.
7. Data transfers as per legal requirements.
8. Ensuring that Aadhaar numbers are never disclosed.

We or our affiliates store your information on servers located in India. Data protection laws vary among countries, and we also comply with legal frameworks related to data transfer as required by the Information Technology Act, 2000, and rules made thereunder. When we receive formal written complaints, we respond by contacting the person who made the complaint and work with the appropriate regulatory authorities to resolve any complaints regarding data transfer that we cannot resolve directly.

7. Links to Other Sites

Our site includes links to other websites with privacy practices that may differ from those of www.plebgraph.com . If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

8. Information Sharing with Third Parties

We may engage third-party advertising companies and/or ad agencies to display advertisements when you visit our website. These companies may use information (excluding your name, address, email address, or telephone number) about your visits to www.plebgraph.com to deliver ads on this site and other sites that may be of interest to you.

If you decide to apply for these separate products or services, disclose information to the providers, or grant them permission to collect information about you, their use of your information is governed by their respective privacy policies. It is advisable to assess the practices of these external service providers before utilizing their services. Please note that www.plebgraph.com is not responsible for their privacy practices.

We do not sell or misuse your data, and we ensure that your data remains protected from access by unrelated third parties. We do not share your personally identifiable information and government IDs with these parties. However, we may enter into data-sharing agreements with third parties to enhance our offerings and provide loan and repayment services.

8.1 3rd Party Service Providers

We collaborate with third-party service providers to carry out various functions within the App, and we may share your information with these service providers to facilitate the operation of the App. Some of these functions may encompass:

1. Verification and authentication of official documents provided by you.
2. Validation of your preferred bank account and disbursement of loan amounts to you.
3. E-signing of the User Loan Agreement and populating the User Loan Agreement. The information shared with these service providers is retained for audit purposes.
4. Setting up eNACH for autopay.
5. Analyzing customer behavior and automating our marketing and outreach efforts.
6. Detecting and flagging fraudulent activities.
7. Collecting additional information regarding your bank account and statement details if sufficient information has not been provided by you or through other service providers we collaborate with.
8. Manual collection of outstanding amounts owed by you to our Lending Partner.

However, the use of such third-party services is subject to their respective privacy policies and is beyond our control. We strongly recommend reviewing their privacy policies before agreeing to use their services. Your explicit consent will be obtained before sharing personal information with any third party, except in cases where such sharing is mandated by statutory or regulatory requirements.

8.2 Third-Party SDK

Our application includes a link to a registered third-party SDK that collects data on our behalf, and this data is stored securely on a dedicated server for conducting credit risk assessments. We ensure that our third-party service provider implements security measures to safeguard your personal information against loss, misuse, or alteration.

The Plebgraph app assesses the current transaction status and usage patterns across the workflow with marketing partners such as Facebook, Google, Appsflyer, and WebEngage. These tools offer capabilities to target customers with smart, personalized notifications and retargeting ads on social media and other websites, encouraging customers to complete their journey or utilize our services after a significant period of inactivity. We do not share any personal information with these partners. We share limited information, such as Device IDs, Android IDs, Page status, Location, and Workflow events, with analytics service providers, which is non-personal.

Our registered third-party service provider ensures hosting security by utilizing industry-leading antivirus, anti-malware, intrusion prevention systems, intrusion detection systems, file integrity monitoring, and application control solutions.

8.3 Government Agencies

To verify your creditworthiness and complete the KYC formalities, we may request you to enter certain government-issued ID numbers, such as PAN Number, Aadhaar Card, or Virtual ID (VID) number. Please rest assured that this data remains completely safe and secure with us and is never shared with any third party. However, your information is transmitted to authorized third-party APIs and government websites to enable you to enter the required information and assist us in validating your KYC credentials.

8.4 Law Enforcement Agencies

In the event that any governmental authority or law enforcement officers request or require information, and we deem that disclosure is necessary or appropriate to comply with laws, regulations, or legal processes, we may disclose the requested information.

9. Data Security Measures

By creating a Plebgraph Account, you agree to the processing, storage, usage, and sharing of the data you provide to us and our Lending Partners in accordance with this Policy. Please be aware that if you revoke any necessary permissions or withdraw your consent to process and store information, such as your Plebgraph Account data, Financial and KYC Information, and/or any other information required to facilitate your loan, it may necessitate the discontinuation of our Services to you.

Once you have availed a loan using the App, you cannot withdraw your consent until you have repaid the loan amount and all associated charges in full.

10. Data Subject Rights

10.1 Right to Rectification

If any personal data provided by you is found to be inaccurate, incomplete, or outdated, you have the right to provide us with accurate, complete, and up-to-date data, and we will promptly rectify such data. We strongly encourage you to ensure that you always furnish us with accurate and correct information/data to ensure uninterrupted use of our Services.

10.2 Right to Withdraw Consent

To prevent further data sharing, you can also uninstall the app. Your device may offer controls to manage the information we collect, such as modifying permissions for Camera or Audio access. You will have the choice to grant or withhold consent for the utilization of particular data, restrict disclosure to third parties, data retention, withdraw previously given consent for the collection of personal data, and, if necessary, instruct the App to delete or forget the data.

10.3 Marketing Opt-Out

From time to time, we may send promotional emails or push notifications about our latest offerings and updates. You have the option to opt out of receiving such promotional emails from us by contacting us in writing. You can also opt out of receiving emails and other messages from us by following the unsubscribe instructions provided in those messages. Please note that even if you opt out of receiving promotional information, you will continue to receive non-promotional communications, such as repayment reminders and loan approval messages, etc.

You can opt out of receiving push notifications through your device settings. Please be aware that opting out of push notifications may affect your use of the App.

11. Contact Information for Data Grievance Redressal Officer

Both we and our Lending Partners have appointed a Data Grievance Redressal Officer. Our Data Grievance Officer is Damini Dhanawade and can be reached via email at: www.plebgraph.com.

You can contact the officer confidentially by email to inquire about the treatment of your data by us or our Lending Partner. Our team will respond to your queries and concerns within 48 hours.

12. Contact Plebgraph

If you have any grievances or need to review your information, you can reach us at the following coordinates:

Level 2:

If you are not satisfied with the response or resolution provided by the Customer Service Manager of the Company, you can directly contact the Grievance Redressal Officer of the Company at the following contact details:

Level 3:

If your grievance is not addressed by the Grievance Redressal Officer within 30 (thirty) days, you may appeal to the Nodal Officer using the following contact details:

At all branches, the head office, and on our website, we will post notices informing customers about the escalation mechanism and the Grievance Redressal Officer, including their name and contact details.

13. Changes to Privacy Statement and Your Duty to Inform Us of Changes

This Privacy Statement may change or be amended over time. The latest version of this Privacy Statement is published on this App or Platform, as applicable. We recommend revisiting this page periodically to stay informed of any changes. We will notify you of any significant changes to this Privacy Statement by publishing them on our App or Platform. Your continued use of our services constitutes your acceptance of this amended Privacy Statement. If you do not agree to the terms and conditions outlined in our Privacy Statement, as amended, you must discontinue using our services and inform us.

It is essential to keep your Personal Information accurate and up-to-date. Please inform us of any changes to your Personal Information. For any privacy-related concerns, kindly contact us at privacy@plebgraph.com.