Last Updated: 28/02/2024
NIRA, through this Policy, aims to demonstrate its commitment towards protecting your personal data and respecting your privacy in compliance with the Information Technology Act, 2000 and Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information), Rules, 2011 (“Rules”), Reserve Bank of India’s (RBI) Guidelines on Digital Lending and any other guidelines that maybe issued by RBI from time to time (all of such guidelines, “RBI Guidelines”).
This Policy is applicable to all the information collected, received, possessed, owned, controlled, stored, dealt with, shared with, accessed by, or handled by NIRA in respect of a User. Please read this Policy along with the Terms and Conditions available at https://www.nirafinance.com/terms-of-use .
1. USER ACKNOWLEDGEMENT AND CONSENT
User acknowledges that by accessing the Platform, User expressly consents and confirms to collection, maintenance, usage, handling, storage and disclosure of User information, including sensitive personal data, by NIRA, in connection with the services we offer to you through the Platform (“Services”), in accordance with this Policy.
Users acknowledge that they have the option to not provide or agree to the collection of personal data. If a User chooses to not grant us access to such personal data when requested, we will not be in a position to provide the User with the Services. In such an event, we encourage you to stop using the Services and accessing the Platform. In addition to this, in the event you do not consent to our access to your personal data, we may have to terminate, suspend or limit your access to the Services or Platform or part thereof, as may be the case.
2. PURPOSE OF COLLECTION OF INFORMATION
Our primary goal in accessing, collecting and using your information, is to provide you with a safe, efficient, smooth and customized experience of our Services. More importantly, we only collect and process basic minimal personal information of the User that we consider necessary for providing the Services and enabling your use of our Platform.
In general, you can browse the Website of NIRA without disclosing your identity or revealing any personal information about yourself. However, to create an account on the Platform you will be required to provide us with certain basic minimal information in connection with the Services.
3. WHAT WE COLLECT AND HOW WE USE YOUR PERSONAL DATA
3.1 NIRA collects the following types of data sets from you:
(a) Personal data collected directly from you:
This type of data is the personal data you provide us. You consent to provide us access to such personal data through your continued use of the Services or through interaction over the Platform. This includes: This type of data is the personal data you provide us. You consent to provide us access to such personal data through your continued use of the Services or through interaction over the Platform. This includes:
(i) Identity and Profile-related Data: This includes personal information concerning the personal or material circumstances of an identified or identifiable User, e.g. name, gender, date of birth, password, password validation, marital status, family details, employment verification information and other similar details shared via the Platform.
(ii) Contact data: This includes your email addresses, phone numbers, and postal address. Contact lists on your phone are not accessed.
(iii) KYC data: In connection with the Services and your use of the Platform, we may also require you to share, or we may collect identification documents issued by government or other authorities to you, including details of or pertaining to Aadhaar, PAN card, voter ID, and ration card. For the purposes of completing the KYC, we take one time access of your mobile phone’s camera, microphone, location is taken. With this access, you will be able to upload the images of employment ID, PAN card, KYC and NACH forms for completing the loan application for fast approval and disbursal from our lending partners. For Android users, the access to your mobile phone’s camera or location is taken based on permissions allowed by your device and as set by you. NIRA only uses the access for one time to complete the loan application form. You may revoke access as per your device’s policies and applicable version once the application form is complete.
(iv) Financial data: This will include your past credit history, income details, details of loans issued, or otherwise applied for through the Platform, payments and repayments thereof, your bank account details and bank account statements.
(b) Personal data collected through your use of the Platform and from your device
This type of data is the personal data collected through your use of the Platform and Services, and ancillary data required for the purposes of fraud detection. The information that the Platform collects, and its usage will solely depend on how you manage your privacy controls on your device. It includes:
SMS Data: We collect, transmit and store SMS data from your phone to verify and analyse your financial position, to determine your cash flow, credits, income, and spending pattern. Please note that such data is limited to details of the transactions contained in the SMS. Personal SMS data or sensitive information such as OTP, personal SMSs, account details, etc is filtered out and not stored.
Device Data: The information we collect from your device includes IP addresses, SDK version and mobile network information including carrier name, SIM Serial and SIM Slot, your profile information, time zone settings, location and device information for the purpose of onboarding. We collect information about your device to undertake fraud detection, provide automatic updates and additional security so that your account is not used in other people’s devices.
Usage Data: We track certain information about you based on how you use the Platform and Services. We use this information to do research on our Users' demographics, interests, and behaviours to better understand, protect and serve our Users and improve our Services. This information is compiled and analysed on an aggregated, anonymized basis.
Transaction data: This includes details of transactions that may occur through the Platform or in connection with the Services. For example, transaction data may include the Services you have sought or availed through the Platform or confirmations of such Services.
Marketing and communications data: This includes your preferences in receiving marketing messages from us and our third parties and your communication preferences.
Please note, no biometric data is stored/ collected in the systems associated with the Platform.
(c) Personal Data Collected from Third Parties
This type of data is personal data about you received from various third parties and public sources including our third-party service providers for advertising and User analytics purposes, and other publicly available sources in connection with our provision of Services to you, or in connection with your use of the Platform or Services that you choose to avail. Please note that we do not have any control over personal data that you may choose to make publicly available. For example, if you post reviews, comments, or messages on public sections of the Platform or on an application store (such as the Play Store), you do so at your own risk. We are not liable for any third-party misuse of such data.
4. USE OF PERSONAL DATA
4.1 By using our Platform and submitting your personal data to NIRA, you expressly acknowledge and consent to use of such information in a manner specified under this Policy. Such personal data can be used for various purposes including:
a) To register you as a user of the Platform and verifying User identity;
b) Facilitating User’s usage of Platform and our Services;
c) To manage our relationship with you, including notifying you of changes to any Services;
d) For extension of loan and financial services to the User from regulated entities including but not limited to Banks, NBFC, NBFC-P2P, other financial partners, etc;
e) To ensure compliance with all legal obligations of lending partners, vis-à-vis Know-your Customer, Prevention of Money Laundering, CKYRC requirements, etc for the purposes of facilitation of the loan/financial services;
f) For fraud prevention and detection;
g) To send User surveys and marketing communications that NIRA believes may be of User’s interest;
h) To facilitate for you repayment of the loans or recovery of outstanding payments on behalf of the lending partner;
i) To diagnose technical problems, provide support and help Users in addressing troubleshoot problems;
j) To send and receive communications, show advertisements, notifications and make promotional offers;
k) To prepare reports, review and filing as per applicable laws;
l) To contact Users regarding lenders and the various financial services being facilitated through NIRA, third party services and offers;
m) To understand User preferences, requirements;
n) To permit User to participate in interactive features offered through the Platform;
o) To improve the content, our business and delivery models and protect the integrity of the Platform;
p) To increase/improve the Services offered on the Platform;
q) To ensure compliance with all applicable laws;
r) To respond to court orders, establish or exercise our legal rights, or defend ourselves against legal claims;
s) To perform our obligations that arise out of the arrangement we are about to enter or have entered with you; and
t) To enforce our Terms.
5. HOW YOUR PERSONAL DATA IS SHARED
5.1 Except as required under applicable laws or pursuant to a court/government order or for purposes set forth in clause 5.2 below, any information or data shared by us with third parties shall be undertaken after obtaining your explicit consent, solely to render the Services to you.Except as required under applicable laws or pursuant to a court/government order or for purposes set forth in clause 5.2 below, any information or data shared by us with third parties shall be undertaken after obtaining your explicit consent, solely to render the Services to you.
5.2 We will share your information with third parties to facilitate provisioning of Services by us to you only in such manner as described below:
(a) We may disclose your information to our regulated partners and lenders, including but not limited to Banks, NBFC, NBFC- P2P on the Platform to facilitate the financial services for you;
(b) We may disclose your information to our third-party service providers for providing the Services as detailed under the Terms & Conditions or for recovery of outstanding loans due;
(c) We may share your information with our third-party partners in order to conduct data analysis in order to serve you better and provide services on our Platform;
(e) We may share your data with our affiliates and/or group companies for data processing and analysis;
(f) We and our affiliates may share your information with another business entity should we (or our assets) merge with, or be acquired by that business entity, or re-organization, amalgamation, restructuring of business for continuity of business.
5.3 If you fail to provide consent for sharing of such data when requested by us, we may not be able to provide the Services to you.
5.4 Third parties with whom we may share your data for providing services are available here.
6.1 NIRA may use "cookies" as required on the Website. “Cookies" is a term generally used for small text files a web site uses to recognize repeat users, facilitate the User's ongoing access to and use of the site, allow a site to track usage behaviour and compile aggregate data that will allow content improvements and targeted advertising, preferences etc. Cookies themselves do not personally identify the User, but it identifies User devices. For the purpose of this Policy, Users are informed that cookies also exist within mobile applications when a browser is needed to view certain content or display an advertisement within the application. Generally, cookies work by assigning a unique number to the computer that has no meaning outside the assigning site.
7. WEB BEACONS
The web pages of the Website contain electronic images known as “web beacons”, sometimes called single-pixel gifs and are used along with cookies to compile aggregated statistics to analyse how the Website is used. Web beacons may also be used in some of NIRA’s emails so as to know which emails and links recipients have opened, allowing it to gauge the effectiveness of its customer communications and marketing campaigns.
8. DATA PROTECTION AND SECURITY
8.1 Pursuant to Information and Technology Act, 2000, Rules and RBI Guidelines, NIRA endeavours to protect sensitive personal and personal data of the Users.
8.2 We store and process your personal information on cloud servers located in India. Some of the safeguards we use are firewalls and bit data encryption using SSL, and information access authorization controls. We use reasonable safeguards to preserve the integrity and security of your information against loss, theft, unauthorized access, disclosure, reproduction, use or amendment. To achieve the same, we use reasonable security practices and procedures as mandated under applicable laws for the protection of your information.
9. YOUR LEGAL RIGHTS
9.1 Data Storage and Revocation of Consent
We will store your information and/or data for such period as may be required by NIRA/financial partners to (i) enforce or enable financial partner to enforce its legal rights and obligations against you; (ii) to ensure compliance with its obligations and responsibilities or the financial partner’s obligations and responsibilities under applicable laws, as specified by the RBI.
9.2 Data Retention
You agree and acknowledge that your personal data will continue to be stored and retained by us as required or permitted by applicable laws or as required for defending future legal claims against us or our financial partners. All the other details will be deleted upon your request for the deletion of the data, provided there is no active loan or Service being availed by you.
9.3 Data destruction protocol
You can request the erasure of your personal data. This enables you to ask us to forget personal data. We shall comply with any request, subject to applicable laws, retention of any data required to defend us in a future legal action, and the terms of the loans that are sanctioned through the Platform.
10. UPDATE USER INFORMATION
Users are required to update their information available with NIRA as and when there are any changes. Users are also entitled to review the information provided and ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient be corrected or amended as feasible.
11. TRANSFER OF PERSONAL DATA
Please note that all your data, including financial data, is only stored on systems located in India. We shall not transfer your personal data to any third country.
12. THIRD-PARTY WEBLINKS
14. GRIEVANCE REDRESSAL OFFICER
NIRA has designated a Grievance Officer. Users can contact the Grievance Redressal Officer with respect to any complaints or concerns regarding the handling, storage, or disclosure of User Information.
Grievance Officer Name: Goutham R
Email address: email@example.com
Contact number: +91-95137-23121
The Grievance Officer can be contacted between 10:30 a.m. to 6:00 p.m. from Monday to Friday except on public holidays.
15. COMPLAINTS TO LENDER
If the grievance is not resolved by NIRA within ten days of lodging the grievance, or if the customer is not satisfied with the response received from NIRA the customer may approach the Lender to have such grievance resolved. The grievance redressal mechanism of the lender is accessible at the below mentioned links:
Muthoot Finance: https://www.muthootfinance.com/customer-service
Northern Arc: www.northernarc.com/grievance-redressal-mechanism