Privacy Policy

2) Personal Data We Collect

Personal data means any data about an individual who is identifiable by or in relation to such data. Depending on how you interact with Paisa 108, we may collect the following categories of personal data:

• Identity and Account Information: Name, title, age, gender, date of birth, user ID, login credentials, and account details.
• Contact Information: Mobile number, WhatsApp number, email address, residential address, office address, and communication preferences.
• KYC and Identification Information: PAN, Aadhaar-related information where permitted by law, photograph, identity proof, address proof, GST details, and other documents required for verification.
• Financial Information: Bank account details, income details, salary details, employment details, financial statements, repayment information, UPI details, e-NACH details, payment details, and transaction history.
• Credit and Lending Information: Loan application details, credit bureau information, credit score, credit history, risk assessment data, repayment behaviour, eligibility data, and information received from credit information companies, account aggregators, partner lenders, or service providers as permitted by applicable law.
• Transaction and Payment Information: Payment gateway ID, payment mode, issuing bank, transaction amount, transaction date, transaction status, repayment status, merchant or service details, and related payment metadata.
• Usage and Technical Information: IP address, browser type, device type, operating system, device model, time zone, login records, app usage events, page views, navigation path, cookies, and similar technical identifiers.
• Marketing and Communication Information: Customer support communications, complaint records, feedback, survey responses, promotional preferences, opt-in or opt-out status, and campaign interaction data.
• Device and Permission-Based Data: SMS data, camera access, location access, phone state, installed app metadata, and other device data only where required for onboarding, eKYC, fraud prevention, credit risk assessment, or regulatory compliance, and only after obtaining required permissions.

We do not intentionally collect data relating to race, ethnicity, religious or philosophical beliefs, political opinions, trade union membership, genetic data, biometric data, sexual orientation, or health information unless such collection is specifically required by law or is voluntarily provided by you for a lawful purpose.

3) SMS, Device, and Phone Data

Where you provide consent, the Paisa 108 app may collect and process SMS data related only to financial transactions, such as bank transaction messages normally received from 5- or 6-digit sender IDs or verified financial institutions. We do not read or collect personal, private, or non-financial SMS messages.

With your consent, the app may collect limited device-related information, including device model, operating system version, RAM, storage, network state, app metadata, and other fraud-prevention signals. We do not collect permanently identifiable device identifiers such as IMEI, serial number, or MAC address unless expressly permitted by applicable law and platform policy.

Camera access is used only for eKYC, document capture, and identity verification. We do not collect or store biometric data through camera access.

Phone State permission may be used only to verify active SIM/network availability during onboarding, disbursement, or fraud-prevention checks. We do not use this permission to access call logs, contacts, or unrelated phone activity.

We display permission notices and consent screens where required, and you may deny permissions. However, denying certain permissions may prevent us or our partner lender from processing your loan application.

4) How We Collect Personal Data

We may collect personal data directly from you when you:

• Register on our website, app, or platform.
• Apply for a loan or credit facility.
• Submit KYC, identity, address, employment, income, bank, or repayment details.
• Use our website, app, payment pages, support channels, or partner platforms.
• Grant app permissions for SMS, camera, location, phone state, or device data.
• Contact us through email, WhatsApp, phone, forms, or customer support channels.
• Participate in surveys, promotions, campaigns, or feedback requests.

We may also collect personal data from lawful third-party sources, including partner lenders, merchants, banks, payment gateways, account aggregators, credit information companies, KYC service providers, fraud-prevention agencies, publicly available sources, and other service providers, where permitted under applicable Indian laws or based on your consent.

5) Legal Basis and Consent

We process your personal data based on your consent, contractual necessity, legal obligations, regulatory requirements, legitimate business purposes, fraud prevention, service delivery, or any other lawful ground available under applicable Indian laws.

Where sensitive personal data or permission-based device data is involved, we will seek your explicit consent before collection or processing, unless processing is required or permitted by law.

You may choose not to provide certain information or may withdraw consent where applicable. However, this may restrict our ability, or the ability of the partner lender, to process your application, provide services, verify your identity, assess creditworthiness, or continue a loan or credit facility.

6) Purpose of Processing Personal Data

We process personal data for the following purposes:

• Verification and Authentication: To verify identity, conduct KYC, authenticate users, prevent impersonation, and create or manage user accounts.
• Loan Facilitation: To facilitate loan applications, eligibility checks, credit assessment, documentation, disbursal support, repayment support, and communication between you and the partner lender.
• Credit Risk Assessment: To assess repayment capacity, detect risk signals, verify income, evaluate creditworthiness, and support underwriting by the partner NBFC.
• Transaction Processing: To process payments, repayments, refunds, settlement, reconciliation, and transaction records.
• Customer Support: To respond to queries, service requests, disputes, complaints, technical issues, and grievance redressal requests.
• Fraud Prevention and Security: To detect, prevent, and investigate fraud, identity theft, device spoofing, unauthorized access, suspicious activity, money laundering, or misuse of services.
• Legal and Regulatory Compliance: To comply with applicable laws, RBI directions, KYC norms, tax requirements, audit requirements, reporting obligations, court orders, law enforcement requests, and regulatory directions.
• Service Improvement: To improve user experience, platform performance, product design, risk models, analytics, and operational efficiency.
• Marketing and Communication: To send service updates, offers, educational content, product information, and promotional communications where permitted by law and your preferences.

7) Disclosure and Sharing of Personal Data

We may share your personal data, where necessary and lawful, with the following parties:

• Partner Lender / Regulated Entity: Siddhi Traders Private Limited, for loan processing, underwriting, KYC, disbursal, servicing, collection, repayment, regulatory compliance, and grievance handling.
• Credit Information Companies: Such as CIBIL, Experian, Equifax, CRIF High Mark, or other authorized credit bureaus, where applicable.
• KYC and Verification Providers: For identity verification, document verification, eKYC, fraud checks, and onboarding.
• Payment and Banking Partners: Banks, payment gateways, UPI service providers, e-NACH providers, and repayment processing partners.
• Technology and Cloud Service Providers: Hosting providers, analytics providers, security vendors, communication vendors, and technical support partners.
• Collection and Customer Support Partners: Authorized service providers assisting with repayment reminders, service support, or complaint handling.
• Regulators and Government Authorities: RBI, law enforcement agencies, courts, tax authorities, statutory bodies, or other authorities where disclosure is required by law.
• Business Transfer Parties: In case of merger, restructuring, acquisition, asset sale, financing, or transfer of business, subject to confidentiality and applicable law.

We do not sell your personal data to advertisers. Any third-party sharing is limited to lawful, disclosed, and purpose-linked processing.

For further details regarding service providers or third parties with whom data may be shared, you may contact us at help@paisa108.com.

8) Marketing Communications

We may send service-related communications, repayment reminders, account updates, policy updates, support messages, and security alerts through SMS, email, WhatsApp, app notifications, phone calls, or other digital channels.

We may also send marketing or promotional communications about our products, services, or partner offerings where permitted by law and based on your communication preferences.

You may opt out of promotional communications by using the unsubscribe option, adjusting your communication preferences where available, or writing to us at help@paisa108.com. Service-related and legally required communications may continue even after marketing opt-out.

9) Data Retention and Deletion

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, provide services, comply with legal and regulatory obligations, resolve disputes, enforce agreements, prevent fraud, maintain audit records, and support business operations.

Partner lenders may retain borrower data during the loan tenure and after closure where required for legal, regulatory, audit, tax, recovery, dispute-resolution, or fraud-prevention purposes.

Data may also remain temporarily in backups, logs, or disaster-recovery systems, with restricted access and deletion according to internal retention schedules.

You may request access, correction, withdrawal of consent, or deletion of your personal data by contacting us. Deletion requests may be restricted where retention is required by law, where dues are outstanding, where fraud or dispute investigation is pending, or where the partner lender is required to retain the data.

How to Submit an Account Deletion Request:

1. Send an email to help@paisa108.com.
2. Use your registered email address or mobile number linked with the Paisa 108 app.
3. Use the subject line: Paisa 108 Account Deletion Request.
4. Include your full name, registered mobile number, and required verification details.

For more information, please visit https://www.paisa108.com/account-deletion.

10) Your Rights

Subject to applicable laws and verification of your identity, you may have the right to:

• Access the personal data we process about you.
• Correct or update inaccurate or incomplete personal data.
• Withdraw consent for specific processing activities where consent is the basis of processing.
• Request deletion of personal data, subject to legal, regulatory, contractual, and loan-related restrictions.
• Raise complaints or grievances regarding processing of your personal data.

To exercise your rights, write to us at help@paisa108.com. You may also contact the Grievance Officer using the details provided below.

Withdrawal of consent or deletion of data may affect our ability, or the partner lender's ability, to provide or continue services, process loan applications, manage repayments, or comply with legal obligations.

11) Storage and Transfer of Data

We store and process personal data on servers located in India, either directly or through authorized service providers. Where any transfer or access outside India is required, it will be carried out only in accordance with applicable Indian laws, contractual safeguards, and regulatory requirements.

We require our service providers, vendors, and partners to protect personal data using appropriate confidentiality, security, and data-protection obligations.

12) Security Measures

We implement reasonable technical, organizational, administrative, and physical safeguards to protect personal data against unauthorized access, misuse, loss, alteration, disclosure, or destruction.

These safeguards may include access controls, encryption where appropriate, secure storage, monitoring, internal policies, vendor controls, audit trails, and incident-response procedures.

No digital platform can guarantee absolute security. You are responsible for keeping your login credentials, OTPs, device access, and account information secure and confidential.

13) Cookies and Third-Party Links

Our website, app, or platform may use cookies, analytics tools, pixels, SDKs, or similar technologies to improve functionality, security, performance, analytics, and user experience.

Our website, app, or platform may contain links to third-party websites, plug-ins, services, or applications. We are not responsible for the privacy practices, content, or security of third-party platforms. You should review their privacy policies before sharing any information with them.

14) Minors

Our services are intended only for individuals who are legally eligible to enter into financial transactions and loan-related arrangements. We do not knowingly collect personal data from minors.

If we become aware that personal data of a minor has been collected without lawful consent, we will take reasonable steps to delete such data, unless retention is required by applicable law.

15) Changes to this Privacy Policy

We may update or amend this Privacy Policy from time to time to reflect changes in law, regulation, technology, products, services, or business practices.

The updated Privacy Policy will be published on our website, app, or platform. Your continued use of our services after publication of the updated Privacy Policy will mean that you acknowledge the updated terms, subject to any consent requirements under applicable law.

16) Consent

By using our website, app, platform, or services, submitting your personal data, or granting app permissions, you consent to the collection, use, processing, storage, and sharing of your personal data in accordance with this Privacy Policy, subject to applicable law.

You may withdraw consent where permitted by law by writing to us at help@paisa108.com. Withdrawal of consent may affect the availability or continuation of services.