Privacy Policy

Introduction

This Privacy Policy is published by Upfin Fintech Private Limited, a company incorporated under the Companies Act, 2013, having its registered office at No. #167, 3rd Floor, 37th Cross, 28th Main, Jayanagar, Bangalore- 560041. Upfin which term, unless repugnant to the context or meaning thereof, (hereinafter referred to as “Upfin’). This Privacy Policy will be applicable in the context of the Upfin’s website (www.upfin.app) and Upfin Application (hereinafter collectively referred to as its "Application") and govern the persons downloading, signing up/registering on the Application and purchasing the various products and services as presented by Affiliate through the Application (hereinafter referred to as "End Customer" or downloading signing up/registering and/or promoting various products and services on the Upfin’s Application to the End Customer (hereinafter referred to as “Affiliate(s)”). (End Customer and Affiliate(s) shall collectively be referred to as "Users").

We at Upfin are committed to protecting the privacy and security of its Users. Users’ privacy is important and maintaining your trust is paramount to us. This Privacy Policy (“Privacy Policy”) explains how Upfin collects, uses, processes, discloses, and safeguards the information of its Users when they access and use Upfin’s services through Upfin’s Application at: (www.upfin.app) which shall be incorporated into and subject to the Terms of Service of the Application and shall be read harmoniously and in conjunction.

Applicable Acts

This Privacy Policy is published in accordance with the relevant provisions of the Information Technology Act, 2000 (hereinafter referred to as the “Act”), Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (hereinafter referred to as the "IT Rules") and the Information Technology (Intermediary Guidelines) Rules 2011 (hereinafter referred to as the "Intermediary Rules") and such other applicable laws.

Through this Privacy Policy, Upfin provides information about the details it collects from Affiliates (including but not limited to personal and sensitive information as described in the IT Rules) hereinafter referred to as "Information" (It is explicitly clarified that the term "Information" shall mean and include the information described in herein.

Information Collected from Affiliates

The purpose of such collection, disclosure of data, the mode of removal or updating Affiliate Information, practices and safety measures and grievance redressal mechanisms in the following manner:

Upfin is engaged in the business of advertising a variety of products and services products on its Application to the Affiliates to enable them to promote the same to End-Customers. For more information about the products and services, please go through the Application.

Upfin collects the following Information from the Affiliates for the following purposes:

  • Name.

  • Access to location – to enable the Affiliate to use the Application.

  • Mobile number.

  • WhatsApp permission for sending a notification, for sharing leads and product related information, messages, invite links etc.

  • Address as per Aadhar.

  • Email ID - for communication purposes.

  • Such other ancillary details connected to the aforesaid.

Information Collected from End Customer

Upfin collects the following information from the End Customer for the following purposes:

Mobile No. – To register end-customer details on the Application before they can proceed to apply to the products and services on the Application;

Name as per Aadhaar Card- to register end-customer details on the Application before they can proceed to apply to the products and services on the Application;

Email Address – for communication purposes to register end-customer details on the Application before they can proceed to apply to the products and services on the Application; and

Pin-code - To register end-customer details on the Application before they can proceed to apply to the products and services on the Application.

Purpose of Collecting information

While the specific purposes are covered above, the generic statement of purpose is as mentioned below:

  • To enable Affiliates and End Customer to use the Application;

  • To enable the Affiliate to withdraw the amount from the bank;

  • To facilitate the transactions or report on these transactions;

  • To undertake research and analytics for offering or improving the products and services and their security and service quality;

  • To check and process Affiliate’s requirements or instructions or requests received from End Customers and/or Advisors in respect of the products;

  • To share with Affiliate any updates on changes to the products/services and their terms and conditions including the Application’s terms and conditions;

  • To verify identity and to provide products and services to the Affiliate;

  • To comply with the requirements of applicable laws/regulations and/or court orders/regulatory directives;

  • To allow Affiliates to sign-up or set-up their account with Upfin; and

  • To initiate legal action in case of breach by Affiliate.

The Information is collected for Upfin to understand the kind of Affiliates and End Customers accessing the Application.

The Information is collected for Upfin to understand the Affiliate and End Customer behaviour and to customize or modify or enhance its services accordingly.

The information is collected for the End Customers to explore and apply for products listed on the Application.

Use of information Collected by Upfin

Upfin neither rents nor sells User personal information in personally identifiable form to anyone. Upfin shares User’s personal information in personally identifiable form with third parties only as described in this Privacy Policy. The Information is stored by Upfin including by its associates/employees and auditors/attorneys (hereinafter referred to as “Authorised Personnel”) and third-party software enabled on the Application in its electronic and physical databases. However, it is hereby clarified that:

Reasonable safety practices as per Indian standards are enabled on the Application (and the Application is encrypted), the electronic and physical databases to protect the data collected by Upfin and to prevent unauthorized access to third parties;

The Authorised Personnel will be provided access to the data only on a need-to-know basis and with an obligation cast on them to protect the confidentiality of such data;

The Information will be used for the purposes described in Clause 5 of this Privacy Policy;

Upfin will not share User personal information with third parties without User permission unless Upfin’s ownership changes or Upfin merges or enters into a joint-venture with another party; or Upfin is required to do so under any law, or in connection with any legal proceedings and/or to defend our legal rights; and

Upfin does not knowingly collect personal and sensitive information from persons aged below 18 years.

Cookies Policy

A “cookie” is a small piece of information stored by a web server on a web browser so it can be later read back from that browser. Cookies are useful for enabling the browser to remember information specific to a given user. Upfin place both permanent and temporary cookies in User’s computer’s hard drive/Mobile. User may choose to set his web browser to refuse cookies, or to alert the User when cookies are being sent. Upfin lets other companies that show advertisements on some of Upfin’s pages set and access their cookies on User’s computer. Other companies’ use of their cookies is subject to their own privacy policies, not this one. Advertisers or other companies do not have access to Upfin’s cookies.

Procedure to Contact Grievance Officer

In case Affiliate wishes to obtain a copy of their personal information or wants to delete or update their personal information or withdraw their consent to publish their Information or if the Affiliate has any grievance pertaining to the Upfin’s Application then such person can contact Upfin’s grievance officer (name) by sending an email or mobile no regarding their request (mention email and contact number of grievance officer) with the subject line as "Acceleration of grievance".

Upon satisfactorily ascertaining the credentials of the person seeking the information, Upfin shall with the Affiliate’s cooperation, assist them in redressing the grievance or request in a timebound manner.

Further, it is clarified that in the event the Affiliate withdraws their consent to publish their Information or makes a request of above-mentioned nature in the manner specified above, Upfin shall at its sole discretion have the rights to disable or restrict or block such Affiliate’s registration or access to the Application.

Data Shared with Third Parties

Upfin may use third-party advertising companies to serve ads when the User visits the Application or Upfin shall post third-party services or products on the Application. When the User applies for such products, the User may be redirected to the said third-party webpage or application.

These companies and third-parties may use information (including but not limited to) the User’s name, address, email address, telephone number, or sensitive personal information) about User’s visit to the Application in order to provide advertisements about the products and services of interest to User.

Further, such advertisements may have hyperlinks that lead to the advertiser’s or third-party’s website. Upfin hereby expressly clarifies that Upfin is not making any warranties and shall under no circumstances be responsible for the privacy safeguards of such websites or applications or the accuracy or authenticity of the data contained in such websites or the advertisements, users are advised to refer to the privacy policies and terms of use of such website and exercise reasonable caution when using such third- party websites.

Acceptance by the User to Privacy Policy

It is hereby clarified that the acceptance to this Privacy Policy and Terms and Conditions is a precondition for the User to visit or use the Application. In the event the User disagrees to provide such it is hereby clarified that the acceptance to this Privacy Policy and Terms and Conditions is a precondition for the User to visit or use the Application.

In the event the User disagrees to provide such acceptance then such User is required to leave/ stop visiting or using the Application immediately. The User’s act of using or visiting the application shall be deemed as acceptance by the User to the Privacy Policy and Terms and Conditions.

Changes to this Privacy Policy

Upfin reserves the right to update or modify all or any part of this Privacy Policy and such update or modification shall (unless specified otherwise) be effective from the date the same is published on the Application. However, Users are encouraged and advised to visit the Privacy Policy section from time to time to ascertain if any update or modification has been made to the same.

Liability in Case of Data Breach and Force Majeure

While Upfin has taken appropriate steps for the security and protection of Application, however, Upfin shall not be responsible for any breach of security or the disclosure of personal data for reasons outside its control, such as hacking, social engineering, cyber terrorism, espionage by third parties, or any events by way of force majeure such as sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war or acts of government.

Cancellation and Refund Policy

If the End Customer wants to cancel any product or service availed by him at any point of time, then the cancellation request should be submitted to Upfin’s Grievance Officer in written manner along with necessary details. If product or service is cancelled or is unavailable due to any reason, before the final payment, Upfin will issue an invoice for the amount of work completed at that point of time, depending on the resources used for that work.

Any payment delay from End Customer’s side or delay in provision of services Affiliate’s end lasting longer than 30 days will be considered as cancelled by Upfin and it will not get restarted unless Upfin receives the request in written to resume the product or service availed. In such cases, Upfin will issue an invoice for the amount of work completed at that point of time, depending on the resources used for that work.

Upfin follows the refund policy as stated below and any client by registering for any of the products or services provided on the Application, agrees to accept the refund policy of Upfin. It is pertinent to note that:

  • This refund policy does not apply to any companies or persons that Upfin does not manage or employ, including third-party service providers or websites;

  • Before filing a complaint for refund, all possible attempts for achieving acceptable solution should be a priority. Refund will be considered as a last resort when nothing is working out between Upfin and its Users;

  • Refund requests will only be considered if Upfin and its End Customers are unable to reach mutually satisfying solution;

  • Upfin provides best possible products and services and in a professional manner so as to deliver results as proposed earlier. However, in adverse conditions, if Upfin is unable to complete End Customer’s requests, then Upfin may provide a refund and the amount paid as refund shall be as per the sole discretion of Upfin; and

  • Refunds will be processed within 4 to 5 weeks after the receipt of request for refund.

Governing Law & Dispute Resolution

Upfin’s services are provided and published by Upfin and are governed by all applicable laws within the territory of India. Any Dispute that may arise in respect of User’s use (directly or indirectly) of Upfin’s Application and/or in respect of this Privacy Policy shall be governed under the respective provisions provided in the Terms and Conditions.

Privacy Questions and Grievance Redresal

If you have any questions, concerns, or suggestions regarding Upfin’s Privacy Policy, please reach out to Upfin using the contact information on Upfin’s “Contact Us” page or at (email address). If you have any grievance or complaint with respect to Upfin’s Application, please reach out to the Grievance Officer, the name and contact details provided below:

  • Name: Subeesh K.
  • E-mail: subeesh@upfin.app