SOP FINANCE PVT. LTD. PRIVACY POLICY

 

Last updated: MAY 2, 2022

PLEASE READ THIS POLICY CAREFULLY BEFORE USING THE APP

Sop pay - jaldi se car loan Get Instant Car Loan App is provided by Sop pay ("our", "us", "we", "Company"), with its registered office at 1,Yash Building, Dindoshi, Nr Dindoshi Fire Station, Goregoan East, Mumbai-400097, India. We (i.e., the Company) and our affiliate partner of NBFC (the "Lending Partner") need to gather different data and information from you in order to provide you with the Services, process your loan requests, and eventually offer a loan to you (and co-applicants, if applicable). This Sop pay Privacy Policy ("Policy") addresses how we (i.e., the Company) and our Lending Partner gather, maintain, share, store, and process this data and information. We reserve the right to alter this Policy as well as update the Services and the App at any time, so please revisit this page frequently to stay up to current on any changes. If you disagree with any element of this Policy, please discontinue your use of our Services immediately.

This Policy incorporates and contains our Terms as well as any Agreement(s) completed by you (and any co-applicants, if applicable) in order to get the loan products made accessible by the Lending Partner ("User Loan Agreement"). Words and phrases not defined in this Policy have the same meaning as defined in the Terms. All references to you (as a user / visitor) must include all co-applicants, if any.

1. INFORMATION ABOUT CONTACT

 

You may reach out to the data grievance officer, at: help@sopfinancegroup.com confidentially to enquire about the treatment of your data.

A data grievance officer has been designated by us and our lending partner. Our data grievance officer may be reached by email at help@sopfinancegroup.com. You can contact the officer confidentially via email if you have any questions regarding how we or our Lending Partner handle your data.

2. WHAT INFORMATION IS COLLECTED?

 

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

 

By using the App, you consent to providing us and our Lending Partner, 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 and tenure for such loans. The data being asked from you helps us and our Lending Partner to provide services to you in a robust and user-friendly manner. We have detailed the manner in which we and our Lending Partner collect data below:

 

S. No.  Means of Gathering Data

          Data Collected

1.     Data you input in the course of signing up and using our Services    Sop pay App Account Data: When you create or update your Sop pay App Account, we and our Lending Partner gather the information you give. This information comprises your name, phone number, email address, PAN, date of birth, pin code, kind of job and employer name, monthly income, marital status, and connection with the co-applicant (in case the loan is being sought by more than a single applicant). We or our Lending Partner may request you to supply more information at a later date to check the accuracy of your information or to take advantage of any new features offered to the App.

This information will be used in the following ways: See, Enabling the App and its Services; Loan Processing and KYC Authentication; Customer Support; Research and Development; Enabling Communications Between You and Us; Marketing and Outreach; Automated Decisions; Legal Compliance and Requirements

Financial and KYC Information: We and our Lending Partner gather the information you submit when you accept the loan's preliminary conditions. This contains your image, Aadhaar Number, PAN, parents' names, bank account number, IFSC, and proof of residence (which can be your power bill, rental/lease agreement, gas bill, passport or driver's license, voter's identification card, or any other document our App can capture).

Other Data Solicited: You may be required to provide further information to the Lending Partner for the purposes of processing your loan application. Such additional information may include (without limitation) bank statements, goods and services tax returns, salary and income statements and title documents for the property being financed. This data shall be supplied to the Lending Partner through us. You may also be required to provide this information to us and the Lending Partner via physical documents, e-mail or other digital and offline methods.

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.

Feedback Data and Other Data: This includes the following:

•     If you call our call centers, we may record information provided by you to service you or record the calls for quality and training purposes.

•     Data you input when you participate in our referral programs or use any discount codes offered by us.

•     If you provide any feedback or comments to us on the App.

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.

2 .    Data we collect from your usage of our Services 

 

Geolocation data: We and our Lending Partner gather location data from you in two ways: I when you enter the pin code as part of your Soppay App Account data, and (ii) when you allow your mobile device to do so. When our App is operating in the background of your mobile device, we acquire this info. If you deactivate location services, you will be unable to use the App.

This information will be used in the following ways: See, for example, Enabling the App and its Services; Loan Processing and KYC Authentication; Customer Support; Marketing and Outreach; Automated Decisions; and Legal Compliance and Requirements.

Personal information about the user: To log in to the app, our app gathers user account data such as email address and name. This information is necessary as part of the registration process to use our service, and it is also used to auto-populate appropriate areas on our app's interface. Our software also gathers mobile phone numbers for verification in order to check the device's active SIM status, uniquely identify you, and prevent fraud and unwanted access.

Phone Book Contacts: When you enable us access to your mobile device's address book, we and our Lending Partner have access to and keep the names and contact information from your address book in order to effectuate invites and analyze your phone usage and patterns. If you disable this access, you will be unable to use the App. We gather all of your phonebook contacts, including their contact names, phone numbers, account types, favorites (starred), and contact labels, as part of the loan process to improve your financial profile. This information is used to calculate your social network from your phonebook contacts and to identify fraudulent contacts in your network. This assists us in detecting fraudulent loan applications and mitigating credit risk.

For more information on how we utilize this data, see Enabling the App and its Services; Loan Processing and KYC Authentication.

Data from Financial SMS: When you enable us access to your mobile device's SMSs, we and our Lending Partner gather SMS data from your device. If you disable this access, you will be unable to use the App.

This information will be used in the following ways: See also Enabling the App and its Services, Loan Processing, and KYC Authentication.

App Data: We and our Lending Partner gather data on your installed applications, including the apps you've installed on and since the day you created your Soppay App Account, as well as how you use them. This includes having access to and authorization to send you messages and notifications through your social networking and instant messaging apps. If you disable this access, you will be unable to use the App.

We utilize this data for a variety of purposes, including: enabling the app and its services; loan processing and KYC authentication; enabling customer support; and conducting research. and Development; For Enabling Communications Between You and Us; For enabling Marketing and Outreach.

Usage data: We collect data about how you interact with our Services. This includes data such as access dates and times, App features or pages viewed, App crashes and other system activity, type of browser, and third-party sites or services used before or in the course of interacting with our Services.

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; For Automated Decisions; For Legal Compliance and Requirements.

Transaction information: We 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. Additionally, if someone uses your promotion code, we may associate your name with that person and their usage of 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.

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.

Storage: This permission is required so that users' documents can be securely downloaded and saved on users' phones and upload the right documents for a faster approval and disbursal of the loan. This helps provide a very smooth and seamless experience while using the app.

3          Information we receive from other sources    We may also be working closely with third parties (such as credit information bureaus, business partners, technical subcontractors, analytics providers, search information providers, title deeds, property verification service providers, and valuers) and may lawfully obtain information about you and your co-applicant from such sources. Such information may be shared internally and coupled with information gathered through the App.

This information will be used in the following ways: See also: Enabling the App and its Services; Loan Processing and KYC Authentication; Customer Support; Research and Development; Communication Between You and Us; Marketing and Outreach; Automated Decisions; Legal Compliance and Requirements.

 

3. WHY AND HOW DO WE USE THE DATA WE COLLECT?

 

In order to offer you with the most up-to-date and effective Services, the Company and the Lending Partner gather and utilize data about you.

 

Here's what we'll do with the information we get in line with that section:

 

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:

•           Complete the Soppay Account setup.

•           Find out if you're eligible for a loan and how much you'll be required to pay in interest.

•           Keep tabs on the loan's distribution and repayment.

•           Add and remove bank accounts for your loan repayments and disbursements by enabling options that allow you to do so at any moment.

•           Check your loan history, credit score (as provided by government databases), and other app capabilities when they become available by enabling the aforementioned options.

•           Execute internal tasks required to deliver our services, such as fixing bugs and identifying operational issues, as well as collecting and analyzing data, performing tests, and conducting research.

2          For Loan Processing and KYC Authentication          Using the information we provide, our lending partner analyses your creditworthiness and loan eligibility, as well as the conditions of your loans. The Lending Partner is required to process and validate each loan request while we gather the financial and KYC information. You won't be able to get a loan if you don't handle this information.

3          For Enabling Customer Support Customer support, including resolving your issues with the Services, and training our customer care representatives are some of the ways we utilise your information.

4          For Research and Development          In the end, this data will help us enhance the App's UI/UX, which in turn will help you enjoy using it more. Our automatic actions can also be triggered in specific scenarios, such as when we need to determine whether photos are not clear, fraud occurs or the IFSC is inaccurate etc.

5          For Enabling Communications Between You and Us            Additionally, we may introduce capabilities that allow you to call us (either through the App or elsewhere) (through the App or any other channels that you give us access to, such as WhatsApp or Facebook).

6          For Marketing and Outreach  Marketing the App and our services may make use of the data we gather. Your comments, ratings, and screen identities will be used only for marketing and promotional purposes. Hoardings, banners, booklets, and other forms of advertising can be used for this purpose.

7          For Automated Decisions       Customers' answers, reimbursement tracking, and other functions might be automated by the app. We want to add additional automatic capabilities to our app as it increases in popularity.

8          For Legal Compliance and Requirements      According to relevant legislation, or as required by regulators, government agencies, and official inquiries we may use your information to investigate or resolve any issues arising from your use of our Services.

9          For Product Innovation           For example, we may use your personal information to offer you new products and services..

 

4. WHAT ARE THE OPTIONS FOR DISTRIBUTION OF THE DATA?

 

Due to the contractual nature of these agreements, we must inform you that your personal information will not be transferred to other parties. This data is used to process information and ensure that you receive the Services.

 

Your personal information is very important to us. Data-sharing agreements or disclosures of the obtained data may be made in order for us to supply you with the Services and new product offerings. Our lending partner and we have outlined how we share the information we've gathered below.:

 

S. No.  Person Shared With    Purpose for Sharing

1          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 your SMS, bank statements, goods and services tax returns, salary and income statements, and income tax returns, on which your loan offer is formed, to examine your transaction activity and cashflows is the first step.

•           Your official verification documents will be authenticated and validated.

•           Verifying and sending the loan funds to your chosen bank account.

•           Electronically signing and filling the User Loan Agreement or Sanction Letter with the user's signature. We keep the data we provide with these service providers for the purpose of auditing our contracts.

•           Setup of eNACH/ NACH to enable automatic payment.

•           Automating our marketing and outreach activities by analysing consumer behaviour.

•           False flagging and detection.

•           In the cloud.

•           Information about your bank account and statement, in case you or our other service providers haven't given us enough information already.

•           Any money owing by you to our lending partner will be collected manually.

Third Party Services: You may be able to connect to third-party websites, goods, or services using the App, over which we have no command (for example, if we allow you to pay through an external wallet facility then we will have to share your usage information with the facility provider). However, we have no control over the privacy practices of third-party services. Before deciding to utilize their services, we urge that you review their privacy policies.

Affiliates and Group Companies: For the purposes of product research and development, advertising of relevant items to you, and customizing products for your advantage, we may share any data we gather from you with our affiliates and group businesses, according to applicable legislation.

 

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.

 

5. WHAT ARE YOUR RIGHTS REGARDING THE DATA?

 

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 help@soppay.com if you wish to exercise any of your rights under the Policy. You shall have the following rights:

 

S. No.  Person Shared With    Purpose for Sharing

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 at our end immediately. 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 your consent to this policy by uninstalling the App. However, if you have availed any loans from our Lending Partner, we shall have the right continue processing your information till such loan has been repaid in full, along with any interest and dues payable.

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          Marketing opt-outs: We may email and notify you from time to time about our latest offerings and updates. You may opt out of receiving such promotional emails from us by writing to us. You may also opt out of receiving emails and other messages from us by following the unsubscribe instructions in those messages. However, even if you have opted out of receiving information from us, we will still send non-promotional communications, such as receipts for amount remittance etc.

Push Notifications: 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.

 

6. WHAT DO WE DO TO PROTECT YOUR DATA?

 

Your personal information and data are important to us, therefore we've invested in the most up-to-date technology.

 

The collection, storage, use, and disclosure of your personal information by us and the Lending Partner are all governed by this Policy, and by creating a Sop payAccount, you agree to these terms. Please email to us at help@soppay.com if you do not agree with any of the provisions of this Policy or the Terms or if you wish to revoke any consent you have given us and/or the Lending Partner. But if you withdraw any necessary permissions or renounce the consent to process and keep information such your Sop payAccount data, Financial and KYC Information and/or any other information needed to enable your loan amounts, we may have to stop providing the Services to you. Once you've used the App to get a loan, you can't take it back until you've paid back the whole loan amount and all associated fees.

 

7. MECHANISM OF CONSENT

 

By submitting an application for a loan, you are agreeing to our whole set of privacy policies. You can contact us at help@soppay.com to cancel any consent.

The collection, storage, use, and disclosure of your personal information by us and the Lending Partner are all governed by this Policy, and by creating a Sop payAccount, you agree to these terms. Please email to us at help@soppay.com if you do not agree with any of the provisions of this Policy or the Terms or if you wish to revoke any consent you have given us and/or the Lending Partner. But if you renounce any necessary permissions or revoke the consent to process and keep information such as your Navi Account data, Financial and KYC information, or any other information needed to facilitate your loan amounts, we may have to stop providing the Services to you. Once you've used the App to get a loan, you can't take it back until you've paid back the whole loan amount and all associated fees.

8. EXTENDING THE LIFE OF YOUR INFORMATION

 

We retain your personal data to the extent we need to. Once the legal basis for the retention expires, we will not hold onto it.

 

We shall retain the information you provide to facilitate your smooth and uninterrupted use of the App, and (i) to provide, improve and personalize our Services; (ii) to contact you about your account and give customer service; (iii) to personalize our advertising and marketing communications; and (iv) to prevent, detect, mitigate, and investigate fraudulent or illegal activities. We do not retain your personal data for longer than required for the purpose for which the information may be lawfully used. For any other information, we may entertain your request for deletion, however, you may not be able to use our Services at all after such deletion.

 

9. CHILDREN'S CONFIDENTIALITY

We do not intentionally seek or collect personal information from anyone under the age of 18 and our services are not geared towards youngsters (eighteen). If we discover that a child has provided us with personal information, we will take the necessary steps to erase the information and cancel the Sop payAccount.

10. CONTACTS WITH US

When we deem it essential, we may send you service-related announcements (such as when we temporarily suspend the App for maintenance, or security, privacy, or administrative-related communications). SMS/push notifications/email/instant messaging are all options we use to notify you.

11. CHANGES TO THIS ADVISORY

This Policy may change from time to time. If you continue to use our services after an update, you agree to be bound by the terms of the new notice. Please check this policy for updates on our privacy practises on a regular basis.