Privacy Policy

This privacy policy (“privacy policy”) sets forth the modes of

collection, use and disclosure of your information gathered on the
platform. This privacy policy applies only to personal information
collected on the platform. This privacy policy does not apply to
information collected by the company in other ways, including
information collected offline. Please read this privacy policy
carefully. by continuing to use the services, or access the platform
you agree to this privacy policy. If you do not agree to this privacy
policy, you may not access the services.
Access to the Platform is subject to the Terms and Conditions
(“T&Cs”) accessible on the Platform, capitalized terms used and
not defined in this Privacy Policy, shall have the same meaning
ascribed to them in the T&Cs.

INTRODUCTION

We Betterplace Safety Solutions Pvt Ltd (“Company”; “We”; “us”;

“our”, “Betterplace”), a company registered under the Companies
Act 2013, have developed a mobile application platform under the
brand name of “Betterplace Money” (“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
authorised 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.

We are committed to protect your privacy and have made this

Privacy Policy to describe the procedures we adhere to for
collecting, using, and disclosing the Personal Information. We
recommend you read this Privacy Policy carefully so that you
understand our approach towards the use of your Personal
Information.

By using Platform, User gives their consent that Company could

collect, disclose, share, and use User’s information in accordance
with the terms of this Privacy Policy, also User consents to be
bound by the terms and conditions of this Privacy Policy.

We recognize the importance of protecting personal details and

information and provide this Privacy Policy with respect to the
access and use of our services. By using our Services through the
app, you signify your assent to this Privacy Policy and consent to
the processing of your Information (Personal Information and/or
Sensitive Personal Data or Information). If you do not agree with
this Privacy Policy, then do not, in any manner, use our Services or
download, install and/or use the mobile application.

GOVERNING STATUTE

This Privacy Policy is governed by and is compliant with the

Information Technology Act, 2000 and Information Technology
(Reasonable Security Practices and Procedures and Sensitive
Personal Data or Information) Rules 2011, which are designed to
protect Personal Information of the end-user(s) of the Services;
and other applicable rules and regulations related to privacy.
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 authorise 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 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

1. Identification Information: Your name, email address, phone

number, any other contact details, government or other
identity documents, date of birth, gender, employment
details etc
2. Other: Other demographic information
3. 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.
4. Storage: Allow you to upload documents and images when
applying for a loan. Also collects and monitors files metadata
to provide you better loan offers
5. Camera: We require camera access so that you can easily
scan or capture required KYC documents and save time by
allowing us to auto-fill relevant data or to initiate an
audio/video call for KYC purpose. This ensures that you are
provided with a seamless experience while using the
application.
6. Collection of device location and device information: We
collect and monitor the information about the location of
your device to provide serviceability of your loan application,
 to reduce risk associated with your loan application and to
provide pre-approved customised loan offers. This also helps
us to verify the address, make a better credit risk decision and
expedite know your customer (KYC) process. Information the
App collects, and its usage, depends on how you manage
your privacy controls on your device. When you install the
App, we store the information we collect with unique
identifiers tied to the device you are using. We collect
information from the device when you download and install
the App and explicitly seek permissions from You to get the
required information from the device. The information we
collect from your device includes the hardware model, build
model, RAM, storage; unique device identifiers like IMEI, serial
number, SSAID; SIM information that includes network
operator, roaming state, MNC and MCC codes, WIFI
information that includes MAC address and mobile network
information to uniquely identify the devices and ensure that
no unauthorised device acts on your behalf to prevent frauds.
We collect information about your device to provide
automatic updates and additional security so that your
account is not used in other people’s devices.
In addition, the information provides us valuable feedback on
your identity as a device holder as well as your device
behaviour, thereby allowing us to improve our services and
provide an enhanced customised user experience to you.

7. Collection of financial sms information: We don’t collect, read

or store your personal SMS from your inbox. We collect and
monitor only financial SMS sent by 6-digit alphanumeric
senders from your inbox which helps us in identifying the
various bank accounts that you may be holding, cash flow
patterns, description and amount of the transactions
undertaken by you as a user to help us perform a credit risk
 assessment which enables us to determine your risk profile
and to provide you with the appropriate credit analysis. This
process will enable you to take financial facilities from the
regulated financial entities available on the Platform. This
Financial SMS data also includes your historical data. While
using the app, it periodically sends the financial SMS
information to our affiliate server and to us.
8. User 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.

The App has a link to a registered third party SDK which collects
data on our behalf and data is stored to a secured server to
perform a credit risk assessment. We ensure that our third party
service provider takes extensive security measures in order to
protect your personal information against loss, misuse or
alteration of the data. Our third-party service provider employs
separation of environments and segregation of duties and has
strict role-based access control on a documented, authorized,
need-to-use basis. The stored data is protected and stored by
application-level encryption. They enforce key management
services to limit access to data.
Furthermore, our registered third party service provider provides
hosting security – they use industry-leading anti-virus, anti
malware, intrusion prevention systems, intrusion detection
systems, file integrity monitoring, and application control solutions

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:

1. detect and prevent fraud;

2. develop and test new products and features;
3. verify information that you have provided;
4. to form a view of you as an individual and to identify, develop
or improve products, that may be of interest to you; 5. delivering
the information and support you request, including technical
notices, security alerts, and support and administrative
messages;
6. diagnose or fix technology problems
7. conduct statistical and market analysis; and
8. satisfy any other legitimate business purposes, including
handling any complaints and retaining information as
necessary to meet our obligations under applicable laws and
regulations.
9. 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;
10.to find adequate references for your loan application; 11. to
give you customised offers as per your location; 12. carry out,
monitor and analyse our business, carry out market
research, business, and statistical analysis and also direct our
efforts for product improvement;
13. to maintain records under applicable law or a may apply to
pursuant to agreements executed by our clients and
partners
14.We may set “cookies” to track your use of the Platform.
 Cookies are small encrypted files, that a site or its service
provider transfers to your device’s hard drive that enables the
sites or service provider’s systems to recognize your device
and capture and remember certain information. By using the
Platform, you signify your consent to our use of cookies.

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.
● Business Partners: We may use certain trusted third party
companies and individuals to help us provide, analyse, and
improve the services including but not limited to data
storage, maintenance services, database management,
credit bureaus, rating agencies, web analytics, payment
processing, and improvement of the Platform’s features.
These third parties may have access to your information only
for purposes of performing these tasks on our behalf and
under obligations similar to those in this Privacy Policy. We
may disclose your Personal Information to partners who
perform business functions or hosting services on our behalf
and who may be located outside India.
● 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 unauthorised 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.
● Legal and Regulatory Authorities: We may be required to
disclose your Personal Information due to legal or regulatory
requirements. In such instances, we reserve the right to
disclose your Personal Information as required in order to
comply with our legal obligations, including but not limited
to complying with court orders, warrants, or discovery
requests. We may also disclose your Personal Information(a)
to law enforcement officers or others; (b) to Credit
Information Companies; (c) to comply with a judicial
proceeding, court order, or legal process served on us or the
Platform; (d) to enforce or apply this Privacy Policy or the
T&Cs or our other policies or agreements; (e) for an
insolvency proceeding involving all or part of the business or
asset to which the information pertains; (f) respond to claims
that any Personal Information violates the rights of third
parties; (g) or protect the rights, property, or personal safety
of the Company, or the general public. You agree and
acknowledge that we may not inform you prior to or after
disclosures made according to this section.
● 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 [email protected] 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
the user when the 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 authorise 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 to
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 unauthorised 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.
Credit Bureau information

You authorise Betterplace to share your personal information with

its group companies and other third parties, in so far as required
for joint marketing purposes/offering various services/report
generations /checking if you have a credit bureau presence with a
credit information company and you also authorise credit
information companies to confirm the fact of your bureau
presence with them.
Repayment

You consent to make the payment as per the schedule. In case

you fail to make the payment, Betterplace reserves the right to
collect money from you. This can be done either internally or
through third parties. The same data would be reported to credit
bureaus which can impact your credit history.

DND Consent

Member agrees to expressly authorise Betterplace to make calls,

even in the case that Member’s contact number is listed as DND
with the concerned telecom regulatory authority.
COMMUNICATIONS FROM THE PLATFORM

● 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 protected]
● 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
INDEMNIFICATION

You agree to indemnify us, our subsidiaries, affiliates, officers,

agents, co-branders or other partners, and employees and hold us
harmless from and against any claims and demand, including
reasonable attorneys’ fees, made by any third party arising out of
or relating to: (i) Personal Information and contents that you
submit or share through the Platform; (ii) your violation of this
Privacy Policy, (iii) or your violation of rights of another customer(s)
or (iv) any acts or omission of yours in relation to the Platform and
its use thereof.
LIMITATIONS OF LIABILITY

You expressly understand and agree that the Company shall not
be liable for any direct, indirect, incidental, special, consequential
or exemplary damages, including but not limited to, damages for
loss of profits, goodwill, use, data, information, details or other
intangible losses (even if the Company has been advised of the
possibility of such damages), resulting from: (i) the use or the
inability to use the Services; (ii) unauthorised access to or
alteration of your Personal Information. The aggregate liability of
the Company to you or anyone, whether in contract, tort,
negligence or otherwise, howsoever arising, whether in
connection with this Privacy Policy, your access and use of the
Platform and its contents and functionalities or for any reason
related to the operation of the Platform, shall not exceed
Rs.10,000.

GOVERNING LAWS AND ARBITRATION

This Privacy Policy shall be construed and governed by the laws of
India and courts of law at Bengaluru shall have exclusive
jurisdiction over such disputes without regard to principles of
conflict of laws. All disputes, differences or claims arising out of or
in connection with this Privacy Policy, shall be referred upon to a
sole arbitrator (to be mutually agreed between the parties) and
finally settled in accordance with the rules of the Arbitration and
Conciliation Act, 1996. The venue of arbitration shall be Bengaluru
and shall be conducted in English language.
CHANGES TO THIS POLICY

We may update this Privacy Policy without notice to you. You are
encouraged to check this Privacy Policy on a regular basis to be
aware of the changes made to it. Continued use of the Services
and access to the Platform shall be deemed to be your
acceptance of this Privacy Policy. This Privacy Policy was last
modified on 7th October, 2022.

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.

GRIEVANCE OFFICER
If you have questions, concerns or grievances regarding this
Privacy Policy, you can reach out to our Grievance Officer,
appointed in accordance with Information Technology Act 2000
and rules made there under. The name and contact details of our
Grievance Officer are provided below:
NAME: Md Akhtar

Address: 8th Floor, IndiQube Vatika, TOWER-B,

VATIKA TOWER, Golf Course Rd, Suncity, Sector 54, Gurugram, Haryana 122003

Email Id: [email protected]