Sarvam Fintech Private Limited, is a private limited fintech company incorporated in India, operating under the brand name of “Scholfe” (“We”/ “Us”/ “Our”) and is engaged in the business of providing easy, transparent and speedy loans using innovative technology solutions (“Services”) to its clients (who shall hereinafter be referred to as “You”, “Your” “User” as applicable). The Services shall be rendered either through its website at https://www.scholfe.com (“Website”) or through various mobile applications that are made available to you (“Applications”) from time to time (the Website and Application shall be collectively referred to as “Platform”).
WHAT CONSTITUTES AS PERSONAL INFORMATION?
When you access our Platform, we collect, store and retain certain potential information for provision of Services, when you fill out the Registration Form to avail our Services, including but not limited to the following:
- Your personal details such as Name, Date of Birth/Age and Gender,
- transaction-related information, such as when you make purchases, respond to any offers, or download or use Applications from us,
- any information you provide us when you contact us for help,
- Login ID and password
- government issued identification document/credentials details, (vii) User details as provided at the time of registration or any time thereafter to us,
- Financial information such as salary details, bank documents, bank statements, PAN card, bank account no., data from Credit Information Companies (Sensitive Personal Data), data required for Know Your Customer, e-KYC data, requirements, etc
- Your usage details such as time, frequency, duration and pattern of use, features used and the amount of storage used and any other information that is willingly shared by you or is essential for rendering our Services and
- details of the activity you look-up on our Platform.
- Storage of customer data including the type of data that can be held, the length time data can be held, restrictions on the use data, data destruction protocol, standards for handling security breach ,etc.
In addition to the above, the following information is defined as “Personal Information” is defined under Information Technology (Reasonable Security Practices & Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”) to mean any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person.
Data security is our priority. To prevent unauthorised access, we have the required procedures and firewalls (both electronic and physical) to
safeguard your data.
1.Move quickly to secure the systems and fix vulnerabilities that may have caused the breach.
2.Switch off the servers and change the access code to prevent additional data loss
3.Mobilize the breach response team right away to prevent additional data loss.
4.Additional security required will be placed.
5. Securely delete personally identifiable information (PII) and other sensitive data when it no longer needed for business purposes
The SPDI Rules further define “sensitive personal data or information” of a person to mean personal information about that person relating to the following: (i) passwords; (ii) financial information such as bank accounts, credit and debit card details or other payment instrument details; (iii) physical, physiological and mental health condition; (iv) sexual orientation; (v) medical records and history; (vi) biometric information; (vii) information received by body corporate under lawful contract or otherwise; (viii) visitor details as provided at the time of registration or thereafter; and (ix) call data records. (The points above shall be collectively referred to as “Personal Information“).
HOW IS PERSONAL INFORMATION COLLECTED?
We may collect information either actively, as described above, or passively. To improve the responsiveness of the Platform, as you navigate through a website, certain information can be passively collected (that is, gathered without your actively providing the information) using various technologies and means, such as Internet Protocol addresses, cookies, Internet tags, and navigational data collection.
The Website may use Internet Protocol (IP) addresses. An IP Address is a number assigned to your computer by your Internet service provider so you can access the Internet and is generally considered to be non-personally identifiable information, because in most cases an IP address is dynamic (changing each time you connect to the Internet), rather than static (unique to a particular user’s computer). We use your IP address to diagnose problems with our server, report aggregate information, determine the fastest route for your computer to use in connecting to our site, and administer and improve the site.
A “cookie” is a bit of information that a website sends to your web browser that helps the site remember information about you and your preferences. You can set your browser to reject cookies, however not all aspects of the site may be available to you if you choose to do so.
“Session” cookies are temporary bits of information that are erased once you exit your Web browser window or otherwise turn your computer off. Session cookies are used to improve navigation on websites and to collect aggregate statistical information. This site uses session cookies.
“Persistent” cookies are more permanent bits of information that are placed on the hard drive of your computer and stay there unless you delete the cookie. Persistent cookies store information on your computer for a number of purposes, such as retrieving certain information you have previously provided (e.g., passwords), helping to determine what areas of the website visitors find most valuable, and customizing the website based on your preferences.
“Internet tags” (also known as single-pixel GIFs, clear GIFs, invisible GIFs, and 1-by-1 GIFs) are smaller than cookies and tell the website server information such as the IP address and browser type related to the visitor’s computer. This site uses Internet tags. Tags have been placed both on online advertisements that bring people to the site and on different pages of the site. These tags indicate how many times a page is opened and which information is consulted. We do not collect or seek personally identifiable information through these tags.
“Navigational data” (“log files,” “server logs,” and “clickstream” data) are used for system management, to improve the content of the site, market research purposes, and to communicate information to visitors. This site uses navigational data.
Please be informed that we use the following cookies:
“Preference Cookies” to remember your preferences and various settings.
“Security Cookies” We use Security Cookies for security purposes.
We ensure that we do not store personal information of borrowers except some basic minimal data (viz., name, address, contact details of the customer, etc.) that may be required to carry out our operations
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.
We ensure that all data is stored only in servers located with in India.
We shall be responsible regarding data
privacy and security of the customer’s personal information in terms of storage.
OTHER DATA COLLECTED:
- Further, we may also collect information that your browser sends whenever you visit our Platform or when you access Service by or through any device (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When you access our Platform with a device, this Usage Data may include information such as the type of device you use, your device unique ID, the IP address of your device, your device operating system, the type of Internet browser you use, unique device identifiers and other diagnostic data.
- We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Services, to improve and customize our Service. You can enable or disable location services when you use our Services at any time by way of your device settings.
HOW DO YOU CONSENT TO OUR USE OF YOUR PERSONAL INFORMATION?
We ensure that we desist from accessing mobile phone resources like file and media, contact list, call logs, telephony functions from borrower phone resources.
We ensure that only for business need basis only one time access will 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 borrower
USAGE OF PERSONAL INFORMATION
Our primary goal in collecting your Personal Information is to provide you with a smooth, efficient and customized experience. This also allows us to provide our Services and features that are most likely to meet your needs, and to customize the Platform and our Services in a hassle-free manner to you.
We use the Personal Information collected from you for the following: (a) to provide and maintain our Services; (b) to notify you about changes to our Services;(c) to allow you to participate in interactive features of our Services when you choose to do so; (d) to provide customer support; (d) to gather analysis or valuable information so that we can improve our Services; (e) to monitor the usage of our Services; (f) to detect, prevent and address technical issues; (g) to fulfil any other purpose for which you provide it; (h) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; (i) to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.;(j) to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information; (k) in any other way we may describe when you provide the information and (l) for any other purpose with your consent.
We collect personal information which includes but is not limited to name, mailing address, phone number, credit card number, pan number, Aadhaar number, bank account number, passport details, ITR, Bank Statements, purpose of loan and other financial information. We may ask you to provide additional information about yourself, if required for the purpose of rendering our services.
1.Online and electronic interactions via the Application, text messaging programs or applications on third party social networks.
2.Offline interactions via collecting PDCs (if required), NACH mandate.
We ensure that we do not collect / stored biometric data in our systems unless allowed under extant statutory guidelines.
ACCESS AND DELETION OF PERSONAL INFORMATION
When you sign up for our Services, you are opting in to receive emails, text messages and/or WhatsApp messages from us. We will take reasonable steps to accurately record the Personal Information that you provide to us and any subsequent updates. As a user, you have the right to access, correct, delete or transfer your Personal Information that we hold, including registration details.
We will securely store the information collected from user excluding the data mentioned in the Archiving / removal clause of the policy until closure of the account with Scholfe, for us to offer better services and products on ongoing basis
To ensure that personal data is kept for no longer than necessary, the organisation shall delete the KYC documents like PAN, Aadhar and
other OVD Documents of the user possessed for processing their loan application within 48 hours from date of disbursement or rejection of the application.
We are providing an option to give or deny consent for use of specific data, restrict disclosure to third parties, data retention, revoke consent already granted to collect personal data and if required, make the app delete/ forget the data.
The user can also reach the organisation to delete his account and information by mailing us email@example.com subject to closure of all the ongoing services
RETENTION OF PERSONAL INFORMATION
DISCLOSURE OF PERSONAL INFORMATION
We will share your Personal Information with only our registered third parties including our regulated financial partners for provision of Services on the Platform and/or for facilitation of a loan / facility to a User. We will share your Personal Information with third parties only in such manner as described below:
- We share Your Personal Information with our third-party partners in order to conduct data analysis in order to serve You better and provide services or Products on our Website;
- We will disclose the Personal Information provided by a User with other technology partners to track how the User interact with Website on Our behalf.
- We will disclose the Personal Information to our third-party technology and credit partners to perform credit checks and credit analysis like Credit Bureaus or third-party data source providers;
- We will share your Personal Information under a confidentiality agreement with the third parties and restrict use of the said Personal Information on by third parties only for the purposes detailed herein.
- By using the Platform, you hereby grant your consent to the Company to share/disclose your Personal Information (i) To the concerned third parties in connection with the Services; and (ii) With the governmental authorities, quasi-governmental authorities, judicial authorities and quasi-judicial authorities, in accordance with applicable laws of India.
Disclosure of personal information, we
may share your data if required for statutory or regulatory requirement as an
We will report security breaches to concerned authority & stakeholders in a timely manner.
In case we use or disclose your Personal Information for any purpose not specified above, we will take your explicit consent.
LINKS TO THIRD PARTY WEBSITES
Our Services are not intended for use by children under the age of 18 (“Child” or “Children”). We do not knowingly collect personally identifiable information from Children under the age of 18 years. If you become aware that a Child has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from Children without verification of parental consent, we take steps to remove that information from our servers.
While using our Platform, you hereby agree not to, by any means (including hacking, cracking or defacing any portion of the Platform) indulge in illegal or unauthorized activities including the following: (i) restrict or inhibit any authorized user from using the Platform; (ii) use the Platform for unlawful purposes; (iii) collect information about other users without their express consent; (iv) copy and/or reproduce any part of the Platform without our prior authorization; (iv) engage in spamming or flooding; (v) transmit any software or other materials that contain any virus, time bomb, or other harmful or disruptive component; (vi) remove any copyright, trademark or other proprietary rights, owned by us and contained in the Platform; (vii) use any device, application or process to retrieve, any data stored; and/or (viii) permit or help anyone without access to the Platform to use the Platform through your username and password or otherwise.
We use the information to understand your credit profile and provide you with a better service.
We will not sell or distribute your information to third parties unless we have your explicit permission to do so.
The Organisation shall ensure that personal data are adequate, relevant, and limited to what is necessary in relation to the purposes for which they are possessed.
CONFIDENTIALITY OF PERSONAL INFORMATION
The Personal Information collected from you will, at all time during retention, be maintained by us (including its employees, representatives, partners, etc) in strict confidence and we will take all necessary precautions to protect your Personal Information both online and off-line, and implements reasonable security practices and measures including certain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of our business.
However, please take note that, we do not undertake any liability for any un-authorised use of your account and password. If you suspect any unauthorized use of your account, you must immediately notify us by sending an email to firstname.lastname@example.org. You shall be solely liable to indemnify us due to any loss suffered by it due to such unauthorized use of your account and password.
Notwithstanding the above, we shall not be responsible for the confidentiality, security or distribution of your Personal Information by our partners and third parties outside the scope of our agreement with such partners and third parties.
Officer Name: Santhosh Venkatrajan
Contact No: +91 953-887-2222
The Grievance Officer can be contacted between 10:30 a.m. to 6:00 p.m. from Monday to Friday except on public holidays.
Lending Partner Grievance Officer Details
Axis Finance Limited:
Grievance redressal officer
Ms. Mangal Sarang
Email id: email@example.com
Axis finance Limited
C-2 wadia International center
Avanse Financial Services Limited:
Grievance Redressal Officer (GRO)
Avanse Financial Services Limited,
001 & 002 Fulcrum, A-Wing,
Ground Floor, Sahar Road,
Next to Hyatt Regency,
Mumbai – 400 099, Maharashtra.
Tel No.: 022 68599999
Your use of the Platform will also be to our Terms and Conditionsanthosh venkatrajan