1. Introduction
The document outlines the protection principles and procedures for security and management of
personal
data. The document is part of the overall Information Security policies of the organization.
UGRO Capital Ltd (Ugro) may collect and store information about users or applicants
interested to avail Ugro
services when you visit our website, use our services, or other online promotions /
advertisements.
The policy is prepared in line with the RBI Digital Lending Framework dated August 10, 2022 ;
considers UIDAI
guidelines and regulations ; aligned with Personal Data Protection bill 2021 (draft). The
policy may be updated
from time to time in line with the company’s requirements. Ugro reserves the right to change
or update this
policy at any time on our site. Such changes shall be effective immediately upon posting to
this site.
1.1. Applicability
This policy is applicable to all the personal data collected and managed by various business
functions not
limited to Customers, Loan products, services, business development partner or agents,
Employees,
vendors and any other individuals.
2. Personal Data and Privacy
2.1. Personal information “Definition”
Personal Data – personal data’ means any information relating to an identified or
identifiable natural person
(‘data subject’); an identifiable natural person is one who can be identified, directly or
indirectly, in particular
by reference to an identifier such as a name, an identification number such as Aadhaar card,
PAN, Driving
license no., Electoral card number etc, location data, or other online identifiers, cell#,
Company name, location
or other KYC information.
2.2. Cookies
Cookies are required to be Accepted and enabled in browsers to allow smooth experience (If
cookies are not
selected may affect certain or all web site functions. Cookies and other commonly are used
for data collection
technologies on our websites and in our newsletters and emails to collect information on
both an aggregate
and individual basis.
Ugro may collect some information automatically, which include:
- IP address
- Information about your web browser software and version;
- General geographic location indicated by your IP address;
- Website that referred you to us, and similar information.
- Frequency of visits to our web site;
- Average length of visits;
- Pages viewed during a visit.
We may combine your information, automatically gathered information and the information we
collect
through cookies/web beacons / web bugs, including information that we have collected about
you, or
information that we have obtained from other sources. We may aggregate required statistics
or data that are
collected, to improve customer service experience.
2.3. Collection and Use of Personal data
Ugro collects information that you supply to us when you choose to use “Contact us” form on
our website or
email us for more information or when you register or fill in your contact details for any
services. This
information typically includes your name, company name, email address and other contact
data.
Ugro may use the personal information that is collected to provide requested products and
services and for
our internal business purposes, including, but not limited to:
- Responding to your requests for our unique products and services;
- To process your transactions and to provide you with transaction and post
transaction-related
services, providing, improving, and marketing our products and services, including site
content and
performance;
- Evaluating your use of the services;
- Providing New products and service offers that might interest you;
- Responding to your requests for information;
- Communicating with you by e mail, postal mail or courier, and/or telephone about
products or
services that may be of interest to you;
- Maintaining and managing your account with us;
- Keeping you updated on the issues that are relevant to your relationship with us;
- Monitoring your compliance with any terms and conditions associated with our products
and services,
including to confirm your identity;
- Performing other functions as described to you at the time of collection or pursuant to
your consent.
2.4. Consent to “Personal Data” use
By filling up “Contact us” details or sending any email requesting Product or service
Information, it implies that
you are allowing Ugro Consent to use the supplied information for further process and
offering our range of
Products and services.
In case, as an Applicant or User seeking information, you fill up the Physical Form and
submit at a Ugro Branch
or through a Digital Lending Agents (DLA) or Loan Service providers (LSP), you agree to
giving Consent to use
the supplied information for further process and offering our range of Products and
services.
Consent Revocation option is available, should you wish to withdraw the consent given. Basis
your revocation
request, Ugro shall have limitation to offer you General Information only.
Further processing or furnishing of detailed product or service information based on custom
requirements
based on your profile may not be feasible.
2.5. Sharing of Personal data
Personal data collected and / or stored with Ugro is shared in the manner described in this
Privacy Policy may
involve the transfer of your personal information to Ugro or to authorized third parties of
Ugro such as Digital
Lending Agents (DLA) or Loan Service providers (LSP) or business partners for the purpose of
accepting
applications, process and management of user experience or customer data to deliver
requisite services.
We may share personal information with organizations or individuals that perform functions on
our behalf.
For example, service providers may process data for verification services or may store and
process data on our
behalf. With your consent, we may share your basic information, PAN, Name not restricted to
only these
details, eg when sharing for CIBIL score with credit information companies registered under
the Credit
Information Companies (Regulation) Act, 2005. The service providers are granted authorized
need-based
access or shared relevant Personal information for the purpose of performing their functions
for Ugro.
Ugro may share personal information in connection with a substantial corporate transaction,
such as mergers,
acquisition, the sale of our business, a divestiture, consolidation, or asset sale, or in
the unlikely event of
bankruptcy.
2.6. Storing of Personal data
Ugro keeps your personal information for so long as is necessary in light of the purpose for
which it was
originally collected or lawfully further processed by third parties.
The criteria we use to determine the period of time for which your personal information may
be kept include:
- The nature and type of personal information that you provide to us;
- The purpose for which you provide your personal information to us;
- The necessary business and operational requirements to continue to provide services or
functionality
you have requested
- The information may be retained for a longer time period if required to do so by law,
Regulator and
legal agencies.
2.7. Legal Matters
Ugro may share personal information in response to a court order, a request for cooperation
from a law
enforcement or other government agency, or as otherwise required by law; to persons acting
as authorized
representative capacity on your behalf; to defend against legal claims; to investigate,
prevent, or take other
action regarding illegal activity, suspected fraud, suspected violations of terms and
conditions associated with
any of our products or services, or other wrongdoing; or to protect and defend the rights,
property or safety of
our company, our users, our employees, or others.
2.8. Personal Data Protection
UGRO uses commercially reasonable security measures (including physical, electronic and
procedural
measures) and assure that Personal data shall be safeguarded against loss, misuse, damage or
modification
and unauthorized access or disclosure or breaches.
However, no system for transmitting or storing information electronically can be completely
secure, therefore
guarantee cannot be explicit that personal information or that other communication channels
are secure.
All the information collected during course of services will be held, stored and purged in
accordance with the
standard protocols as defined by the Ugro Information Security policies or the governing
bodies of the land.
We assure that Third parties (DLA or LSP) of Ugro shall follow and uphold the principles of
Personal data
protection as per Digital Lending framework of RBI and ensure that required data protection,
security
measures as required are being taken and complied to by respective partners.
2.9. Data Subject Rights - Individual Rights
As an individual whose Personal or Contact details are stored with us, certain INDIVIDUAL
RIGHTS are allowed,
these are
- Right to access of information
- Amend personal data
- Delete personal data
- Receive or Unsubscribe from promotional mailers
Important Note - Ugro may ONLY service any such requests, if coming from authorized
persons or
representatives of the individual and further actions are subject to terms and conditions of
our Agreements,
service contracts, appointment letters or any other.
Amend or Deletion request shall be processed if, it does not violate Ugro needs for
providing business services
and to retain required personal data as defined by law and legal agencies.
If you wish to exercise your rights or you have any questions related to Privacy, please
email to us
at privacy@ugrocapital.com.
3. Compliance
Any violation to this policy is subject to disciplinary action. The specific disciplinary action depends upon the
nature of the violation, the impact of the violation on informational assets and related facilities, etc. Violations
shall be handled as per the existing HR processes and could range from a verbal reprimand, to termination of
employment/contract and/or legal action.
If a department or function is unable to comply with any requirements detailed within this policy, an exception
shall be obtained. Such exceptions shall be documented, indicating the rationale for the exception and the
related risks. Exceptions to this policy shall follow the exception process for prior authorization and approval.
