PRIVACY POLICY

Speel Finance Company Private Limited (“our”, “us”, “we”, “Company”), is an RBI registered NBFC offering digital personal loans through the Digital Lending App : “Pocketly” (Pocketly Infotech Pvt. Ltd). (“Pocketly”, “App”), and having its registered office at 2-3, Zal Complex, Residency Road, Sadar, Nagpur – 440001.

In order to facilitate and provide you with the Services through the Pocketly App, we (i.e., the Company), need to collect various data and information from you with your prior and explicit consent. The manner in which this data and information is collected, retained, shared, stored, and processed by us (i.e., the Company), are addressed in this Privacy Policy (“Policy”). By setting up an account on the Pocketly App, you agree to the processing, storage, usage and sharing of the data provided by you pursuant to this Policy.

We may revise this Policy as well as update the Services and the App from time to time, so please keep visiting this page regularly to take notice of any changes we make.

If you do not agree with any part of this Policy, please stop using our Services immediately. Please also read our Terms of Use (“Terms”), which describe the terms under which we provide our Services and the terms under which you can use our Services.

You can learn more further below in this Privacy Policy about the ways in which we share information with our Lending Partners. This Policy applies to all our Services unless specified otherwise.

This Policy, incorporates, and includes our Terms and the Agreement(s) executed by you for availing our Services. Words and phrases not defined in this Policy shall mean the same as provided in the Terms.

WHAT DATA IS COLLECTED?

Summary: We, collect certain information provided by you, some of which is sensitive personal information. We have detailed what data and the manner in which this data is collected.

By using the App, you consent to providing us with your prior and explicit consent, data in the ways listed below. We collect the data you provide to ensure that we can provide you Services in the best manner possible. Our Lending Partner uses this data to underwrite (i.e., assess the risk it will be taking) any loan it might offer you and to determine the rates for such loans. The data being asked from you helps us to provide services to you in a robust and user-friendly manner. We have detailed the manner in which we and our Co-Lending Partners, if any, collect data below:

S. No.	Mode of Collecting Data	Data Collected
1	Data you input in the course of signing up and using our Services	Pocketly Account Data: We collect the data you provide to us when you create or update your Pocketly Account. This includes your name, phone number, email ID, PAN, date of birth, pin code, nature of employment, official employment email address and name of employer, monthly income and marital status. We may require you to share further information on a later date to confirm the veracity of your information or pursuant to any additional features added to the App. How we use this data: See, For Enabling the App and its Services; For Loan Processing and KYC Authentication; For Enabling Customer Support; For Research and Development; For Enabling Communications Between You and Us; For enabling Marketing and Outreach; For Automated Decisions; For Legal Compliance and Requirements Financial and KYC Information: We collect the data you provide to us when you accept the tentative terms of the loans. This includes your photograph, Aadhaar Number, PAN, parents’ names, bank account number, IFSC, proof of address (which can be your electricity bill, rental/lease agreement, gas bill, passport or driver’s license, or any other document our App may be able to record). How we use this data: See, For Enabling the App and its Services; For Loan Processing and KYC Authentication Partner and; For Legal Compliance and Requirements; For enabling and servicing of Loan Products from out Lending Partner. Other Data Solicited: You may be required to provide further information to us for the purposes of processing your loan application. Such additional information may include (without limitation) bank statements, goods and services tax returns, salary and / or income statements. This data shall be supplied to the Lending Partner through us. How we use this data: See, For Enabling the App and its Services; For Loan Processing and KYC Authentication; For assessing the quantum and interest rate of loan to be extended; For Legal Compliance and Requirements; For enabling and servicing of Loan Products from our Lending Partner. Feedback Data and Other Data: This includes the following: If you call our call centres, we may record information provided by you to service you or record the calls for quality and training purposes. If you provide any feedback or comments to us on the App or as part of our research programs for improving the App. How we use this data: See, For Enabling the App and its Services; For Loan Processing and KYC Authentication; For Legal Compliance and Requirements. Geolocation data:We collect the location data from you in two ways: (i) when you add the pin code as part of your Pocketly Account data; and (ii) from your mobile device when enabled by you to do so. We collect this data when our App is running in the background of your mobile device. You will not be able to use the App if you disable the location services. How we use this data: See, For Enabling the App and its Services; For Loan Processing and KYC Authentication; For Enabling Customer Support; For Enabling Marketing and Outreach; For Automated Decisions; For Legal Compliance and Requirements; For enabling and servicing of Loan Products from our Co-Lending Partner. User Personal Information: The App collects user account data which includes email address, name to log in to the app. This information is required as part of the registration process to access our service and it is also used to auto populate relevant fields in the course of the interface of our app. The App also collects mobile numbers for verification to check the active SIM status on the device, uniquely identify you and prevent fraud and unauthorized access. How we use this data: See, For Enabling the App and its Services; For Loan Processing and KYC Authentication; Marketing and Outreach Financial SMS Data: When you grant us access to the SMSs on your mobile device, then we, collect SMS data stored on your mobile device. You will not be able to use the App if you disable this access. We read and securely store your SMS data to analyse your financial profile, process your loan requests, and assess your loan eligibility in order to give you the best loan offer. This is further detailed below in Question 2 of this Section 1 of this Policy titled ‘How and Why is the Collected Data Used’. How we use this data: See, For Enabling the App and its Services; For Loan Processing and KYC Authentication; For enabling and servicing of Co-Lending Products with our Co-Lending Partner.
2	Data we collect from your usage of our services	Usage data: We collect data about how you interact with the Services. This includes data such as access dates and times, App features or pages viewed, App crashes and other system activity How we use this data: See, For Enabling the App and its Services; For Enabling Customer Support; For Research and Development; For Enabling Communications Between You and Us; For Automated Decisions; For Legal Compliance and Requirements. Transaction information: We, and Co-Lending Partner, if any, collect transaction information related to the use of our Services, including the type of Services requested, date and time the Service was provided, loan availed, interest payable, EMI selected, and payment method. How we use this data: See, For Enabling the App and its Services; For Loan Processing and KYC Authentication; For Enabling Customer Support; For Research and Development; For Enabling Communications Between You and Us; For Enabling Marketing and Outreach; For Automated Decisions; For Legal Compliance and Requirements; For enabling and servicing of Loan Products from our Lending Partner. Device data: We collect data about the devices used to access our Services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion data, and mobile network data. How we use this data: See, For Enabling the App and its Services; For Enabling Customer Support; For Research and Development; For Enabling Communications Between You and Us; For enabling Marketing and Outreach.
3	Information we receive from other sources	We may also be working closely with third parties (including, for example, credit information bureaus, business partners, partner banks and financial institutions, technical sub-contractors, analytics providers, search information providers, verification service providers) and may lawfully receive information about you from such sources. Such data may be shared internally and combined with data collected on the App. We may also use the content you have shared publicly, including on third party platforms or applications, to promote our Services (including by quoting your content, reviews and/ or recommendations, or displaying screenshots of your content, reviews and/ or recommendations). How we use this data: See, For Enabling the App and its Services; For Loan Processing and KYC Authentication; For Enabling Customer Support; For Research and Development; For Enabling Communications Between You and Us; For enabling Marketing and Outreach; For Automated Decisions; For Legal Compliance and Requirements; For enabling and servicing of Co-Lending Products with our Co-Lending Partner.

HOW AND WHY IS THE COLLECTED DATA USED?

Summary: The Company collects and uses data collected from you to ensure that the Services are as up to date as possible and provided in the most optimal manner to you.

S. No.	Reason of Use	Manner of Use
1	For Enabling the App and its Services	We use the data collected to personalize, maintain and improve our Services. This includes using the data to: Create and update the Pocketly Account. Analyze your loan eligibility and estimate your loan terms. Track the disbursement and repayment of the loan. Enable features that allow you to add and remove bank accounts for your loan repayment and disbursements from time to time. Enable features that help you check your loan history and other such App features as may be added from time to time. Perform internal operations necessary to provide our Services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.
2	For Loan Processing and KYC Authentication	We use the data to analyze your creditworthiness, loan eligibility, KYC documents, current employment verification and the terms of your loans. We collect the Financial and KYC Information, are required to individually process the loan requests and verify the KYC documentation received. Failing to process such data means that you cannot be provided any loans. For this purpose, you hereby consent to voluntarily submit KYC documents, including aadhar related documents in the manner required by us and our Co-Lending Partner, if any, and as issued by the Unique Identification Authority of India (“UIDAI”). You hereby grant us explicit consent to fetch your KYC (Know Your Customer) details from the Central KYC Records Registry using the details provided by you. We also use the data to track disbursement and repayment of your loan.
3	For enabling and servicing of Co-Lending Products with our Co-Lending Partner	We use the data to analyze your creditworthiness, loan eligibility, KYC documents, current employment verification and, and the terms of your loans. You hereby grant us explicit consent to fetch your KYC (Know Your Customer) details from the Central KYC Records Registry using the details provided by you or verify the KYC through authorised government portals. We also use the data for underwriting, to track disbursement and repayment of your loan.
4	For Enabling Customer Support	We use the information to provide customer support, including to resolve your concerns from the use of the Services, and train our customer service executives.
5	For Research and Development	We may use the data so collected for research, analysis, and product development to improve the UI/UX experience – all of which will ultimately improve how you experience the App. This also helps us develop automated actions to be triggered in certain events, such as when we need to identify if photographs uploaded are not clear, fraud takes place, IFSC is incorrect etc.
6	For Enabling Communications Between You and Us	We may add features that allow you to call us (through the App or otherwise), similarly, we may also need to contact you (through the App or any other channels that you give us access to).
7	For Marketing and Outreach	We may use the data we collect to market the App and our Services. This includes sharing your feedback, ratings and screen names for purely promotion and marketing purposes. Even if your name appears in the Do Not Call or Do Not Disturb Register, we may contact you through e-mails, telephones, messages, SMS, WhatsApp or any other available modes for app support, informing about various financial or investment products or any other aspect pertaining to any loan availed by you. You acknowledge that (i) such communication will not cause any inconvenience to you.
8	For Automated Decisions	The App may provide automated features for customer responses or feedback, etc. As our App grows, we will keep adding more automated features to the App
9	For Legal Compliance and Requirements	We may use the data we collect to investigate or address claims or disputes relating to use of our Services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
10	For Product Innovation	We may use the data we collect to offer new products and services for your use.

HOW DO WE SHARE THE COLLECTED INFORMATION?

Summary: Please note that while none of your data is sold, it is shared with third parties on a contractual basis. This data is shared for processing of information and ensuring that you receive the Services. We do not participate in any data marketing contracts.

We are very protective about your data. We may enter into data-sharing agreements or disclose the collected data in order to provide the Services and new product offerings to you. We have detailed the manner in which we and the Lending Partner share the collected data below:

S. No.	Person shared with	Purpose for Sharing
1	Sharing with the Lending Partner	We work with one Digital Lending Application - Pocketly, to provide loan products on the App, and we may share your information with such Digital Lending Application. The Pocketly App is a digital lending application facilitating loan transactions between our customers and details of all our LSPs and DLA are available on the website
2	Sharing with law enforcement when needed	If any governmental authority or law enforcement officers request or require any information and we think disclosure is required or appropriate in order to comply with laws, regulations, or a legal process.
3	Sharing with third parties	Service Providers: We work with third party service providers to execute various functionalities of the App and we may share your information with such service providers to help us provide the App. Some of these functionalities may include: Analyzing transaction behavior and cashflows via your SMSs, bank statements, salary and income statements, income tax returns, basis which your loan offer is generated. Validating and authenticating the official verification documents provided by you. Validating your preferred bank account, as well as transferring the loan amounts to you. E-signing of the loan agreement or sanction letter, populating the loan agreement or the sanction letter. The information shared with these service providers is retained for auditing of the agreements. Analyzing customer behaviour, conducting research into customer behaviour and contacting the customers for the said purpose, and to automate our marketing and outreach efforts. Detection and flagging of fraud. Cloud services. Gathering of additional information regarding your bank account and statement details, in case adequate information has not been provided by you or through the other service providers we work with. For manually collecting any sums owed by you to our Lending Partner. Validating and authenticating your employment status, employment information and employment duration.

RETENTION OF YOUR PERSONAL DATA

The Company will retain data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain this data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

We shall preserve the records pertaining to the identification of the borrowers and their addresses obtained while opening the account and during the course of business relationship, for at least five years after the business relationship is ended.

You may write to us in case you want us to remove your data from our records. We will ensure to fulfil your request subject to any requirement of retaining information as per applicable law.

SECURITY OF PERSONAL DATA

The security of your Personal Information is very crucial to us. It is our endeavor to protect your Personal Information against any type of unauthorized usage. To do this, Pocketly has adopted measures like internal reviews of the data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized system access where your personal information is stored. Pocketly has taken measures applicable under law to protect your information. We have implemented technical controls like firewall, encryption, password, WAF, SOC, Anti-virus etc. and management controls like access management, log review, NDA etc. for better safety of the information given by you.

Pocketly or its Lending Partners do not store the card details (Card Number, CVV, Validity etc.) in its servers.

Pocketly may share information with other third parties under strict confidential/non-disclosure agreement, but won’t be liable for the security breach of the third party. Pocketly cannot also be held responsible for the loss or damage to you, as a result of you providing the information to third parties.

Further, all transactions of suspicious nature and/ or any other type of transaction notified under The Prevention of Money-Laundering Act, 2002, shall be reported to the appropriate law enforcement authority, as the same reaches our knowledge.

YOUR CONSENT

By submitting your personal information, you consent to the use of that information by us as detailed in this policy. You hereby expressly and irrevocably authorize Pocketly / its partners / affiliates to collect, store, share, obtain and authenticate any aspect of your personal information / KYC either directly or through any of the authorized agencies and disclose such information to our agents /contractors / service providers and to also use such information in the manner that may be required by Pocketly/ its partners / affiliates including for the purposes of grant of credit facility and for purposes of its business and for such time period as we may deem fit. In this regard, you expressly and irrevocably authorize Pocketly/ its partners / affiliates to collect, use, verify and authenticate your personal identity information / KYC in any manner without any notice to you.

WHAT ARE YOUR RIGHTS REGARDING THE DATA?

Summary: We have identified your rights in the table above and the manner in which you may exercise these rights.

It is important for us that you remain in control of your data. Please write to us at care@help.speelfinance.com(Click here to complain) if you wish to exercise any of your rights under the Policy. You shall have the following rights:

S. No.	Your right	Details
1	Right to rectification	In the event that any personal data provided by you is inaccurate, incomplete or outdated then you shall have the right to provide us with the accurate, complete and up to date data and have us rectify such data. It may take up to 7 days to process your request. We urge you to ensure that you always provide us with accurate and correct information/data to ensure your use of our Services is uninterrupted.
2	Right to withdraw consent	You have the right to withdraw specific consents you have provided under this Policy by writing to us at care@help.speelfinance.com. Should you do so, you may not be able to access some of the features or pages of the digital platform applications. However, if you have availed any services from our Lending Partners, we shall have the right to continue processing your information. However, we shall not retain your data and information if it is no longer required by us and there is no legal requirement to retain the same. Do note that multiple legal bases may exist in parallel, and we may still have to retain certain data and information at any time.
3	Right to opt-out	You can opt out of receiving push notifications through your device settings. Please note that opting out of receiving push notifications may impact your use of the App.

CHILDREN’S PRIVACY

Our Services are not directed to children, and we do not knowingly solicit or collect personal information from persons under the age of 18 (eighteen). If we find out that a child has given us personal information, we will take steps to delete that information and terminate the relevant Pocketly Account.

COMMUNICATIONS FROM US

We may from time to time contact you via calls, SMS, emails, and other communication channels to provide you with information pertaining to our Services, notifications on updates vis-à-vis our Services (when we consider it necessary to do so), educational information and promotions. We may also notify you if we need to temporarily suspend the App for maintenance, and keep you informed on security, privacy, or administrative-related communications. By setting up an account on Pocketly, you consent to us contacting you via call, SMS, push notifications, or through any other communication channel, as we may deem fit.

UPDATES TO THIS NOTICE

We may occasionally update this Policy. Use of our Services after an update constitutes consent to the updated notice to the extent permitted by law. Please take the time to periodically review this Policy for the latest information on our privacy practices.

CONTACT INFORMATION
Summary: You may reach out to the Privacy officer, confidentially to enquire about the treatment of your data by writing to care@help.speelfinance.com
In addition, you may contact:
1. Grievance Redressal Officer of Speel Finance by writing to: support@speelfinance.com for raising any grievances relating to any transactions with us;