INTRODUCTION We, Onionlife Private Limited (“Company”; “We”; “us”; “our”), a company registered under the Companies Act 2013, have developed a mobile application platform under the brand name of “KarmaLife” (“Platform”) through which you may became member of Platform and apply for a short term loan (“Loan”) to be granted by various non-banking financial company or Banks (“Lender”), based on the loan agreement executed between you and Lender. Lender has appointed and authorized us to collect, store, authenticate, verify and distribute the Personal Information (defined below) as may be required by Lender to sanction the Loan. The Personal Information shall be collected through the mobile application form available on the Platform.
We provide services only within the territory of India and to corporations and individuals in India. We do not market or intend to provide our services to individuals or entities outside the territory of India and accordingly do not use information shared by individuals or entities outside the territory of India. Accordingly, we are governed and shall comply with all data protection laws applicable in India.
Personal Information Collected In order to access the services, you are required to register with the Company by logging in through Third Party Platforms (defined below) (“User Account”). During the application process, you shall be required to share/upload certain personal information such as your name, e-mail address, gender, date of birth, mobile number, mobile phone information , financial information such as PAN card (for KYC purposes), bank account no., data from Credit Information Companies, data required for Know Your Customer compliances, requirement and other relevant details (“Personal Information”) and thereby also providing your prior and explicit consent for collection of aforementioned data by such. You undertake that you shall be solely responsible for the accuracy and truthfulness of the Personal Information you share with us. As part of the services, if required, you authorize us to import your details and Personal Information dispersed over Third Party Platforms. For avoidance of doubt, it is clarified that currently we do not procure your details and Personal Information from Third Party Platforms, however, you authorise us to access such data as and when necessary for providing you the services. “Third Party Platforms” are social networking platforms, such as Facebook, LinkedIn and other similar platforms.
You understand and acknowledge that the Company reserves the right to track your location during the provision of the services, and also in the event that you stop, cease, discontinue to use or access the services, through the deletion or uninstallation of the Platform from the mobile or otherwise, till the event that your obligations to pay the Outstanding Amount(s) to Lender, exist. Deletion, uninstallation, and/or discontinuation of our services, shall not release you from the responsibility, obligation and liability to repay the Outstanding Amount(s). We will collect the below mentioned Personal Information from you. While some information has to be mandatorily provided, others are optional and certain portions of the information will remain private and some will be displayed to other users; We shall always let the User know which is which. Additional information may be gathered during subsequent use of the Platform by the you, whenever you choose to provide it. You shall be provided with an option to give or deny consent for use of specific data, restrict disclosure to third parties (except for cases where such sharing is required as per statutory or regulatory requirement), data retention, revoke consent already granted to collect personal data and if required, make the app delete/ forget the data.
Information We Collect from You/Your Device
- Identification Information: Your name, email address, phone number, any other contact details, government or other identity documents, date of birth, gender, employment, educational background.
- Other: Other demographic information
- Transaction Information: We collect information about payment transactions, the names of the transacting parties, a description of the transactions and the payment or transfer amounts, billing and shipping information, and the devices and payment methods used to complete the transactions.
- Location Information: Through our applications, we collect information about the location of your device.
- Device Information: We collect specific information about your device when you access our Services, including your storage, hardware model, operating system and version, unique device identifier, list of installed apps and their usage history, wifi information, battery information, calendar information, user profile information, mobile network information, and information about the device’s interaction with our services.
- Use Information: We collect information about how you use our Services, including your access time and Internet Protocol (“IP”) address.
We desist from accessing mobile phone resources like file and media, contact list, call logs, telephony functions, biometric data (unless allowed by regulatory authority) etc. for all the new User onboarded on the Platform. However, if you are an existing User, we may have obtained or accessed such data for the purpose for providing the services effectively. In case you require us to delete such data then you may reach out to us in the manner provided under section for Data Retention. A one-time access may be taken for camera, microphone, location or any other facility necessary for the purpose of on-boarding/ KYC requirements only, with the explicit consent of the User.
Information We Collect From Other Sources We also collect information about you from third parties, including third-party verification services, credit bureaus and publicly available sources. In some circumstances, where lawful, this information may include your government-issued identification number. This includes, without limitation, the receipt and exchange of account or credit-related information with any credit reporting agency or credit bureau, where lawful, and any person or corporation with whom you have had, currently have, or may have a financial relationship, including without limitation past, present, and future places of employment and personal reporting agencies. We will also collect information related to your tenure, role, remuneration and other work-related details from your current employer.
Use Of Personal Information We shall use the Personal Information in the following cases: (i) to provide you with the services and to assist you in the event you need additional support; (ii) to access your credit worthiness (iii) to more effectively provide services to you; (iv) to improve the services provided to you; (v) to maintain and manage your User Account; (vi) to assist you with technical difficulties that may arise in relation to your use and access of the Platform; (vii) to manage our relationship with you; (viii) for internal analytics purpose. (ix) to comply with our legal or statutory obligations; (x) to contact you about important announcements and other important information about your User Account, the Platform and the services. In addition, some other uses of your Personal Information are as per below:
- Detect and prevent fraud
- Develop and test new products and features
- Verify information that you have provided
- To form a view of you as an individual and to identify, develop or improve products, that may be of interest to you
- Delivering the information and support you request, including technical notices, security alerts, and support and administrative messages
- Diagnose or fix technology problems
- Conduct statistical and market analysis
- Satisfy any other legitimate business purposes, including handling any complaints and retaining information as necessary to meet our obligations under applicable laws and regulations.
- To get in touch with you when necessary and contact you by email, SMS, letter, telephone or in any other way about our products and services
- To find adequate references for your loan application
- To give you customized offers as per your location
- Carry out, monitor and analyse our business, carry out market research, business, and statistical analysis and also direct our efforts for product improvement
- To maintain records under applicable law or a may apply to pursuant to agreements executed by our clients and partners
Disclosures We do not sell, rent, lease your Personal Information to anybody and will never do so. Keeping this in mind, we may disclose your Personal Information in the following cases:
- Administrators: We shall provide access to your Personal information to our authorized administrative(s) for internal business purposes, who shall be under confidentiality obligations towards the same.
- Affiliates: We may provide Personal Information we collect to our affiliates. For example, we may disclose Personal Information to our affiliates in order to respond to your requests for information or the services, or to help limit your receipt of marketing materials you have requested not to receive.
- Joint Marketing Arrangements: Where permitted by law, we may share your Personal Information with joint marketers with whom we have a marketing arrangement, we would require all such joint marketers to have written contracts with us that specify the appropriate use of your Personal Information, require them to safeguard your Personal Information, and prohibit them from making unauthorized or unlawful use of your Personal Information
- Persons Who Acquire Our Assets or Business: If we sell or transfer any of our business or assets, certain Personal Information may be a part of that sale or transfer. In the event of such a sale or transfer, we will notify you.
- Notwithstanding anything mentioned hereinabove, the Company shall not be responsible for the actions or omissions of the service providers or parties with whom the Personal Information is shared, nor shall the Company be responsible and/or liable for any additional information you may choose to provide directly to any service provider or any third party.
Data Retention We will retain your Personal Information for as long as your registration with us is valid and the Outstanding Amount(s) is due and payable to Lender. We may also retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Subject to this section, we will try to delete your Personal Information upon reasonable written request for the same. Please note, however, that there might be latency in deleting Personal Information from our servers and backed-up versions might exist even after deletion.
In case you do not wish/want us to collect, disclose, share and use users’ information, including but not limited to any Personal Information, you may choose not to register for an account or terminate your account on the Platform in accordance with the applicable T&Cs available on the Platform.
You have the right to demand us to erase your Personal Information and we will do so without undue delay, provided that the data is no longer required by us and there is no legal requirement to retain the data. Do note that multiple legal basis may exist in parallel and we may still have to retain certain Personal Information at any time, despite your request to delete it.
You may write to us at firstname.lastname@example.org to withdraw your consent to any specific data processing. However, please note that, you may not be able to access certain parts of the Platform, as well as certain services on the Platform if you withdraw your consent. Do note that multiple legal basis may exist in parallel and we may still have to retain certain Personal Information at any time, despite your withdrawal request.
Subject to the above, we will delete all other Personal Information including the banking details (debit/credit card), and passwords of user when User Account is terminated.
Accessing and Modifying Personal Information In case you need to access, review, and/or make changes to the Personal Information, you shall have to login to your User Account and change the requisite details. You shall keep your Personal Information updated to help us better serve you.
Ancillary Services We may provide you with certain ancillary services such as chat rooms, blogs and reviews for the primary services. Subject to any applicable laws, any communication shared by you via the Platform or through the blogs, reviews or otherwise to us (including without limitation contents, images, audio, financial information, feedback etc. collectively “Feedback”) is on a non-confidential basis, and we are under no obligation to refrain from reproducing, publishing or otherwise using it in any way or for any purpose. You shall be responsible for the content and information contained in any Feedback shared by you through the Platform or otherwise to us, including without limitation for its truthfulness and accuracy. Sharing your Feedback with us, constitutes an assignment to us of all worldwide rights, titles and interests in all copyrights and other intellectual property rights in the Feedback and you authorize us to use the Feedback for any purpose, which we may deem fit.
Data Protection We value your Personal Information, and protect it on the Platform against loss, misuse or alteration by taking extensive security measures We have up-to-date physical security, such as secure areas in offices; electronic safeguards, such as passwords, firewalls, and encryption; and procedural safeguards to prevent ID theft.
We may use cloud services such as Amazon Web Services (AWS) or Google Cloud Platform (GCP) to store your personal data. Information you and our partners provide and receive during the services is transmitted through a secure sockets layer (SSL) transmission. We carefully select and monitor partners, who have access to Personal Information, and we have specific provisions in our contracts requiring them to keep it safe and secure. We do not allow them to use or share the information for any purpose other than provide the services to you.
We restrict access to your Personal information only to those employees who are required to know such information in order provide our Services to you. We train our employees on all our security procedures, and we conduct audits to check compliance.
You must also ensure the security of your information such as keeping passwords secret and not permitting unauthorized use of your account. You are responsible for all actions that take place under your User Account. If you choose to share your User Account details and password or any Personal Information with third parties, you are solely responsible for the same. If you lose control of your User Account, you may lose substantial control over your Personal Information and may be subject to legally binding actions.
No security measures can provide absolute protection of data, but we will strive to protect your information. Although we provide appropriate firewalls and protections, we cannot warrant the security of any Personal Information transmitted as our systems are not hack proof. Data pilferage due to unauthorized hacking, virus attacks, technical issues is possible and we take no liabilities or responsibilities for it.
If you choose to use our blog or our Social Network pages (Facebook Fan page, Twitter, LinkedIn, Google Play Store, Apple iTunes store etc), any information you submit can be read, collected, or used by other users of these sites. We are not responsible for the subsequent use of information, which you have submitted to the said sites, by its other users.
The collection, usage, and sharing of Personal 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.
Communications from the Platform We do not sell, rent, lease your Personal Information to anybody and will never do so. Keeping this in mind, we may disclose your Personal Information in the following cases:
- Special Offers and Updates: We may send you information on products, services, special deals, and a newsletter of the Company. Out of respect for your privacy, we present you with the option of not receiving these types of communications. You may unsubscribe via the unsubscribe mechanism provided in each such communication or by emailing us at email@example.com
- Service Announcements: On certain occasions or under law, we are required to send out service or Platform related announcements. We respect your privacy, however you may not opt-out of these communications. These communications would not be promotional in nature.
- Customer Service: We communicate with customer(s) on a regular basis to provide requested services and in regard to issues relating to their User Account, we reply via email or phone, based on customer(s) requirements and convenience
Age Restrictions The Services provided by the Company or the Company Partner (as applicable) are only intended for Users who are 18 years of age or older. If you are not of the requisite age you are not to provide any User Information or other information to the Company. If it comes to the Company’s attention, that any User Information or information shared pertains to an individual under the age of 18 years, such User Information or information will be deleted without notice to you.
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