Privacy Policy

 

BAJORIA FINANCE PRIVATE LIMITED, a corporation organized and existing in the India (“we”, “us” or “our”) takes your privacy very seriously. This privacy policy (this “Privacy Policy”) describes what information we collect from you, the purposes for which we collect and process it, how we use it, who we share it with, how long we retain it, and your rights in relation to it. You should read and understand this Privacy Policy in its entirety. 

This Privacy Policy applies in connection with your use of the Pinjaman Lekas mobile application found here (the “Pinjaman Lekas App”) and your use of our services through thePinjaman Lekas App or otherwise.

Lender Information

Your loan is provided by our authorized lending partner, BAJORIA FINANCE PRIVATE LIMITED.
* Corporate Identification Number (CIN): U67120WB1947PTC015615
* NBFC Registration Number: B-07.65820
* Registered Address: 10 Clive Row, Kolkata, West Bengal 700001
As a licensed NBFC, BAJORIA FINANCE PRIVATE LIMITED ensures that all loans facilitated through this app follow the applicable laws and RBI regulations, giving you a secure and reliable borrowing experience.

1. What personal data doesPinjaman Lekas collect and process? From where doesPinjaman Lekas collect your personal information?

Pinjaman Lekas collects the following personal data (as defined under applicable law), including personally identifiable information:

• Identification data (e.g., first name, surname, date of birth, image);
• Data provided by you through your responses (e.g., information and documents about your income or employment, your educational attainment, information about your mobile device);
• Contact details (e.g., address, phone number, alternate phone number, email address);
• Government-issued identification data and documents (e.g. PAN Card);
• Mobile device specifications (e.g., IMEI, IP address, or other device identifiers, type of device, device operating system, device settings, user account information for your mobile device, the name and network information of your mobile network provider, device specifications (such as screen size, resolution, storage size, etc.));
• Location data (e.g., mobile device location);
• Transaction data and financial information (e.g., loans, payments, loan requests, tax information);
• Device behavioural data (e.g., types and nature of mobile applications found on your mobile device);
• Telecommunications usage data (e.g., subscription data, payment details, applications and usage data, telco score);
• Pinjaman Lekas App usage (e.g., traffic (volume) data, information about your usage or non-usage of thePinjaman Lekas App);
• Information related to your communications withPinjaman Lekas (e.g., your communications withPinjaman Lekas via in-app chat, email, telephone or other channels);
• Information provided by you in relation to participation in special offers and promotional activities conducted byPinjaman Lekas (e.g., promo codes, games, contests, discounts, and participation in by-invitation-only groups);
• Certain third party data (e.g., information provided to or from credit reference agencies or bureaus, external collections agencies, mobile network providers).

Pinjaman Lekas collects your personal data from:

• You, when you download the Pinjaman Lekas App and/or indicate that you want to apply for credit;
• Your other interactions with us, including Information you may voluntarily share with our customer support team or otherPinjaman Lekas employees or agents;
• Your mobile device (through the device permissions is more fully described below); 
• Credit reference agencies (who may check your personal data against other databases – public and private – to which they have access) or fraud prevention agencies;
• Third parties and other publicly available sources, with your consent, when necessary (e.g. we may receive Information from other disbursement channel vendors or other business partners (such as telecommunications companies and credit scoring service providers) that may assist us in providing services to you);
• Third parties who communicate with us through the contact information that you provided to us. 

Collection and processing of your personal data byPinjaman Lekas is necessary for the provision of Pinjaman Lekas’s products and services and to comply with applicable legal and regulatory requirements to which you and/orPinjaman Lekas is subject. Apart from such cases, we do not collect Information without your specific prior consent.

2. What are the purposes for which your personal data is processed? How doesPinjaman Lekas use your personal information?

• To assess your eligibility to use our products or services (including, but not limited to, credit scoring and assessing your creditworthiness, determining whether you can afford a product or service you requested and/or determining whether you are eligible for additional benefits of an existing product);
• To service your account withPinjaman Lekas (including, but not limited to, processing disbursement of your funds and collecting repayment of your outstanding balance);
• To verify your identity and/or other information you provided to us;
• To detect, combat and prevent fraud, attempted fraud, money laundering and/or other illegal uses of our services;
• To analyze customer behavior;
• To administer our systems, maintain service quality and compile general usage statistics;
• To analyze and improve our services;
• To troubleshoot any problems you or other customers encounter with Pinjaman Lekas’s services;
• To comply with applicable laws, regulations, and rules, such as those relating to “know-your-customer” (KYC), customer verification, transaction monitoring, and/or anti-money laundering;
• To send you marketing or advertising notices or other promotional offers, to the extent you have not objected to the use of your personal data for direct marketing purposes after proper notification, to send you marketing or advertising notices or other promotional offers;
• To provide service updates;
• To provide staff training (where we may monitor or record customer interactions);
• To interface with credit reference or fraud prevention agencies;
• To provide customer service or support and to resolve disputes and complaints;
• To contact you by telephone using autodialed or prerecorded message calls or text (SMS) messages (if applicable) as authorized for the purposes described in this Privacy Policy.

We process your personal data for the purposes set out above on the following grounds: 

• To carry out our obligations to you as a result of any contracts or agreements entered into between you and us (i.e., where necessary for the adequate performance of our contract with you and/or to take steps requested by you prior to entering into a contract with you);
• To carry out our legal obligations under applicable law;
• In connection with our legitimate interest in (1) providing you with credit and/or other financial or technological products or services, (2) operating our business, (3) marketing our products and services to you and others and (4) administering our systems and keeping our records up to date;
• With your prior consent. 

3. Who do we share your personal data with?

Pinjaman Lekas will not disclose any Information containing personal data (as defined under applicable law) to any third parties unless it is necessary and/or appropriate in order to provide Pinjaman Lekas's products or services (provided, that, we may share limited personal data (as defined under applicable law) with select partners for research and development). Whenever practically feasible,Pinjaman Lekas will only share your personal data with third parties in an anonymized or de-identified format.

4. For how long will we retain your personal data?

Your personal data will be stored or retained byPinjaman Lekas for a reasonable time necessary for the purposes listed in this Privacy Policy We are required to retain your personal data for a period of at least five (5) years in compliance with anti-money laundering and terrorism financing prevention regulations, notwithstanding requests for deletion. We may also retain your personal data (i) for as long as necessary to comply with any legal obligation; (ii) whenever such is authorized under the law; and (iii) for the establishment of legal defenses. Information that is no longer needed for the purpose(s) for which it was collected shall be deleted or anonymized except as necessary to comply with legal obligations.

5. Where do we process, store or transfer your personal data?

We will ensure that adequate safeguards are in place in accordance with applicable law and/or the Indias’ data protection requirements. The safeguards we will use will depend on the circumstances and the party to whom we transfer your personal data. Your personal data may be processed by any of the parties described above.Pinjaman Lekas will use all reasonable and appropriate efforts as required by applicable law to protect your personal data.

6. Automated decisions and profiling

We may make certain decisions in relation to our provision of our products and services to you by using automated decision-making processes, without human involvement. 

• Credit decisions

When you apply for credit, we’ll use automated processing to decide whether to lend to you and/or make other decisions about your eligibility for our products and services, based on the personal data collected. This automated processing enables us to provide rapid, responsive and tailored credit services to customers who may not have credit histories, prior bank or other financial data or income from formal sources.

Our credit and underwriting models utilize data science and machine-learning technology to process your personal data and assess your creditworthiness. The associated processing of your personal data is automated and little to no human intervention is involved. Using such automated processes to assess your creditworthiness means we may automatically decide that you may be ineligible for our services or ineligible for credit of a particular amount or tenure. Our credit and underwriting models are regularly tested to ensure they remain fair, accurate and unbiased.

• Detecting fraud

Pinjaman Lekas also utilizes automated processes to detect, combat and prevent fraud. Our fraud models may automatically decide that a certain individual poses a fraud or money laundering risk (e.g., if our processing reveals information or behavior consistent with money laundering or known fraudulent activity, if the activity is inconsistent with prior activity on our platform or if an individual appears to be hiding their true identity). If our fraud models determine that processing of a transaction or approving a certain individual creates a risk of fraud, that individual’s access may be suspended or refused.

7. Your rights as a data subject

You may contact us to exercise your rights as a data subject at developer@bajoria-finance.com. Please note that there may be occasions when you wish to exercise your rights and we are unable to agree to your request (e.g., because we have compelling legitimate ground for using or processing your personal data or because we we need to retain your personal data to comply with a legal obligation.

• Right to be informed

We must provide you with certain information related to how we collect your personal data, how we use your personal data (and our legal basis for doing so), who we share your personal data with, where we obtained your personal data and your rights as a data subject. This information is provided within thePinjaman Lekas App and in this Privacy Policy in clear language.

• Right to access

You may ask for a copy of the personal data (as defined under applicable law) we hold concerning you (and your Information related to such personal data), as well as information on how such personal data has been processed, unless providing some or all of it would adversely affect the rights and freedoms of others or applicable law requires that we do not comply with your request. The right to access does not apply to analyses made by thePinjaman Lekas with respect to your personal data, such as inferred, derived, modeled, or business-generated data.

• Right to rectification

You may ask us to correct any personal data which you believe to be inaccurate. We will promptly update any such personal data. In connection with your request, you may be required to provide supporting evidence or other documentation so that we may verify the accuracy of the request.

• Right to erasure or blocking

You may ask us to erase your personal data (as defined under applicable law):

• If you believe it’s no longer necessary for us to retain such personal data;
• If you do not believe we have legitimate ground for processing it;
• If you think we are using such personal data unlawfully;
• If you think applicable law requires that we do so;
• Right to restrict or object to processing

Where the processing of your personal data is based on your consent or our legitimate interest, you may ask us to stop using your personal data (as defined under applicable law):

• if you think such personal data is inaccurate; 
• if you think it’s illegal for us to use such personal data;
• if you don’t want us to destroy such personal data because you need it for legal proceedings;
• if you’ve informed us that we don’t have a legitimate reason for using it and we’re considering your request.

• Right to data portability

If we’re using your personal data on the basis of your consent or because we need it to carry out our contractual obligations to you, you can ask us to give you your personal data (as defined under applicable law) in a structured, commonly-used and machine-readable format or have it transmitted to another data controller. The right to data portability is limited to data that you provided actively and knowingly, or that you provided by virtue of the use of our services. 

• Right to file a complaint

You have the right to file a complaint with the relevant government agencies for any violation of your rights as a data subject. Please note that there may be occasions when you wish to exercise your rights and we’re unable to agree to your request (e.g., because we have compelling legitimate grounds for using or processing your information or because we need to retain your information to comply with a legal obligation).

8. Advertising and Marketing

If you no longer with to receive advertising, marketing or promotional messaging, please contact us at developer@bajoria-finance.com and we will remove you from such communication lists.

9. Consequences of not providing us with your personal data

You are not required to provide us with your Information or any associated personal data (as defined under applicable law) and you may withdraw your consent from the use or processing of such Information or personal data. However, if you do so, we will be unable to provide our current or future products and services to you and we reserve the right to terminate our relationship with you, as permitted under applicable law. Further, to the extent we have a legitimate interest in retaining your Information and/or associated personal data (as defined under applicable law), we may do so. For example, if you have requested that we erase your Information or associated personal data (as defined under applicable law), but you have an outstanding balance withPinjaman Lekas, we may retain your Information or associated personal data (as defined under applicable law), in order to continue collection efforts. We are also required to retain your personal data for a period of at least five (5) years in compliance with anti-money laundering and terrorism financing prevention regulations, notwithstanding requests for deletion.

10. Consent and Authorization

By downloading the Pinjaman Lekas App and clicking “Agree” on the permissions overview screen, you: 

• accept the terms of this Privacy Policy;
• allow Pinjaman Lekas to access the device permissions more fully described below;
• give Pinjaman Lekas consent to collect, use, share, or otherwise process your personal data, which may include personally identifiable information, personal information, sensitive personal information (in each case, as defined under applicable law), as outlined in this Privacy Policy; 
• certify that all personal data you have provided and will provide to Pinjaman Lekas is true and correct to the best of your knowledge; 
• authorize Pinjaman Lekas to verify/investigate the accuracy of your personal data;
• acknowledge that Pinjaman Lekas may be required to disclose your personal data to the Securities and Exchange Commission, Bangko Sentral ng Pilipinas, Anti-Money Laundering Council, Bureau of Internal Revenue, Credit Information Corporation, credit bureaus and/or any other governmental body, in compliance with its legal obligations and in accordance with the principle of proportionality.

11. What device permissions does the Pinjaman Lekas app access? 

Depending on your Device Operating System and the version of the Pinjaman Lekas app installed on your device, the following device permissions may be accessed by thePinjaman Lekas App. Keep yourPinjaman Lekas App updated to make sure you can experience the latest and most secure features.   

• Camera -Pinjaman Lekas will ask you to upload a photo of your ID, proof of income, or a selfie for the purpose of identification. You can choose to take photos on-site (only need Camera permission) or access media library or files to pick a photo (only need Photo permission);
• Location – This helps our fraud models verify your identity. Pinjaman Lekas also uses this information in its credit and underwriting models to determine whether you are eligible for Pinjaman Lekas’s services. We also use location data for research purposes;
• Read phone status and identity – We will collect and use your device ID (advertising ID, BSSID) to ensure the security of your transactions and payments. Granting this permission will help us check if you are performing sensitive actions on commonly used devices. This will effectively reduce the risk of your account being compromised.

Third-party SDKs collect some of our non-sensitive device information (for example: IDFV, IDFA, system version, device manufacturer, brand and model, etc.) for statistical and analytical purposes to optimize our experience onPinjaman Lekas. We only allow third-party SDKs to collect non-sensitive data with your explicit consent;

• Receive text messages – This is used to automatically confirm the one-time password (OTP) sent to your device via SMS;
• Use Camera/Photo album – This permission is needed by the Pinjaman Lekas app to upload photos for KYC;
• View and change network connectivity – This is used to notify the Pinjaman Lekas app when network connectivity changes so that we can determine whether you are connected to internet or not;
• View Wi-Fi connections – Pinjaman Lekas uses the IP address and network type of your device to detect and prevent fraud;
• Receive data from the internet – Pinjaman Lekas needs this permission in order to send requests through the app and to allow the app to access the internet;

12.  General

If you have questions about this Privacy Policy or about your rights as a Data Subject, you can contact our Data Protection Officer at:

Address: 10 Clive Row, Kolkata, West Bengal 700001

Email address: developer@bajoria-finance.com

To improve and continue our services to you and to comply with data privacy regulations that may be issued from time to time, this Privacy Policy may be updated. You can check the latest version by visiting https://bajoria-finance.com and clicking "Privacy Policy" at the bottom.