Privacy Policy

INTRODUCTION

This Privacy Policy seeks to comply with the provisions of the Information Technology Act, 2000 (“Act”) and the Information Technology (Reasonable security practices, procedures and sensitive personal data or information) Rules, 2011 ("Rules") that require publishing of the Policy for collection, use, storage and transfer of sensitive personal data or information.
Lark Finserv Private Limited, a private limited company, referred to as “Company”, “We”, “Us” or “Our” which owns and operates the website www.larkfinserv.com and/or the mobile application and SDKs, ‘LARK’, and ‘LARK FINSERV’, (collectively referred to as the “Platform”).
“You” and “Your” shall mean anyone who visits, accesses, or uses our Platform or obtains Services from Us through our Platform.
We are dedicated to safeguarding Your personal information and privacy while you use and manage the Platform. Because We appreciate Your trust, We uphold the strictest security guidelines to protect Your data and the transactions that take place.
We might also permit Our affiliates, subsidiaries, and group companies to use Our Platform to market their goods and services to You, subject to the terms and conditions that are periodically posted on Our Platform.
This Privacy Policy outlines how the Company will gather, receive, store, process, disclose, transfer, deal with, and handle personal data and other information. The information received from You while accessing the Services through website, mobile app, customer service will be utilised in a manner as set out in this Policy. This Privacy Policy does not apply to information that You provide to, or that is collected by, any third-party (excluding the group companies, affiliates and subsidiary companies) through the Platform, and any Third-Party Sites that You access or use in connection with the services offered on the Platform.
Before using the Platform, registering on it, or accessing or utilizing any of the services it offers, please carefully read the Privacy Policy.
By visiting the Platform, You (“You” or “Your”), accept and agree to be bound by the terms and conditions of this privacy policy (“Privacy Policy”). This Privacy Policy is incorporated into and subject to the Terms of use of the Platform (“Terms”) and shall be read harmoniously and in conjunction with the Terms. We reserve the right to update or modify this Privacy Policy at any time without prior notice and such changes shall be effective immediately
We wish to mention that in case of non-compliance with the privacy policy pertaining to access or usage of the computer resource, We shall have the right to terminate Your right of immediate access or use of the computer resource, your obligation to delete any content that is not compliant, or both, depending on the situation.

2. DATA WE COLLECT ABOUT YOU

With your permission, we gather, transfer, and keep your personal information on our safe servers so that we can offer you the Services. Please be aware that in order to provide you with the Services, we only gather and use a small amount of your personal data.

The information collected on the platform includes:

Identity and profile-related data: This includes your first and last name, parent’s name, husband’s name, date of birth, gender, live photo/video, educational qualifications, purpose of loan, address, employment status, company name, contact information (including addresses, email IDs and phone numbers) and marital status.
KYC/KRA data: This includes identification details such as last 4 digits of Aadhaar, PAN number, signature & documents for identity/address proofs such as Aadhaar, PAN, passport details, Voter ID, driving license, and/or education details.
Financial savings data: This includes your investment in financial assets shares, mutual funds, bonds, insurance.
Financial data: This includes your past credit history, income details, details of loans issued or otherwise applied for through the Platform, payments, and repayments thereof, bank account details, and bank account statements.
Device data: This includes your IP addresses, browser types and versions, cookie, time zone settings, operating systems, and device information. We collect, transmit, and store such data on our secured server.
App data: On our secure servers, we gather, transfer, and keep track of the data from the installed application. The package name of each installed application is the only information we use to determine creditworthiness and create personalized loan offers.
Data from SMSs: We may only gather or keep track of financial SMSs, which assist us in recognizing the different bank accounts you might own, cash flow patterns, and the type and quantity of transactions you as a user have made. These details allow us to conduct a credit risk assessment, which helps us identify your risk profile and provide you with the relevant credit analysis. You will be able to obtain financial facilities through this process from the regulated financial entities listed on the Platform. Your past data is also included in this Financial SMS data.
Transaction data: This includes details of transactions that may occur through the Platform or in connection with the Services. Transaction data could comprise, for instance, confirmations of services you have requested or received through the Platform.

In order to grant you access to the Platform and Services, we must gather your personal data. We may occasionally need to gather personal information as mandated by the Terms or the law. We won't be able to carry out our responsibilities under the agreement we have with you or are attempting to enter into with you if you don't give us that data when we ask for it (for example, to provide you with features of the Services). In this situation, we might have to restrict or terminate your use of the Services (or a portion of them).

3. HOW WE COLLECT DATA ABOUT YOU

Various techniques are employed by us to gather and handle your personal information. This comprises:

Details that you give us: This is the data that you voluntarily provide to us when you use our services or communicate with us (via chat, email, or other means) about identity, contact, KYC, finances, and device usage. It includes the data you submit when you use a platform feature, register to use the services, share data via the platform, or report an issue with the platform or our services. We will maintain a record of the information exchanged during communication with us.
Information we collect about you and your device: Each time you visit the Platform or use the Services, we will automatically collect personal data through the use of tools like cookies.
Information we receive from other sources including third parties and publicly available sources.
Information from third-parties: We or the Financing Partner may also work closely with third parties (including, for example, Mutual Funds RTAs, Demat Depositories, credit information bureaus, account aggregators, business partners, technical sub-contractors, analytics providers, search information providers, etc.) and may lawfully receive information about You from such sources. Such data may be combined with data collected on the Portal and such other information as provided in this Policy. These third parties shall protect user data in accordance with this Policy to an equivalent extent.
Information from third-parties: We may also receive personal data about you from various public sources including our third parties, Google analytics for advertising and user analytics purposes, and other publicly available sources. Please be aware that we have no control over any personal information you decide to make public. Additionally, we might get some personal data in the form of leads or details about possible borrowers from outside sources like digital loan aggregators, middlemen, direct selling agents, etc. (e.g., name, contact details, etc.). By using the aforementioned information, You grant Us access to it, and You grant Us permission to disclose Your personal information in line with this Policy. In order to verify the accuracy of Your information or in order to implement any new features that may be added to the Portal, We may ask You for additional information at a later time.

4. HOW WE USE YOUR PERSONAL DATA AND FOR WHAT PURPOSES

OUR USE OF YOUR PERSONAL INFORMATION AND OUR GOALS

We will only utilize your personal information as permitted by law. Generally, we will use your personal information to fulfill legal requirements or to deliver the Services to you.
By using our Services and registering on the Platform, you consent and acknowledge that we, our associate partners, and affiliates may contact you by phone, email, or other means. This is to make sure you understand every feature of the services.

Generally speaking, we use your personal information for the following uses and actions that are carried out without direct human oversight or control:

To add you to the Platform's user database;
To provide you with the Services;
To facilitate your application to avail loan and otherwise in connection with your obtaining of credit facilities from regulated entities including our lending partners
To manage our relationship with you, including notifying you of changes to any Services;
To administer and protect our business and the Platform, including troubleshooting, data analysis, system testing, and performing internal operations;
To deliver content to you;
To send you communication, including through WhatsApp business messages, in relation to your use of the Platform or Services;
To monitor trends so we can improve the Platform and Services;
To improve our business and delivery models;
To perform our obligations that arise out of the arrangement we are about to enter or have entered with you;
To enforce our Terms;
To undertake marketing services, including sending you promotional messages;
To respond to court orders, establish or exercise our legal rights, or defend ourselves against legal claims;
In compliance with the Reserve Bank of India’s norms, to contact you or locate you in case of any default; and
To ensure compliance with applicable laws.

5. HOW WE STORE AND RETAIN DATA ABOUT YOU

If it is necessary to provide services or for business purposes, we will keep or store user information in India. Information will be kept for as long as required by Indian regulations and applicable laws.
The following categories of data, which are not all-inclusive, may be kept:
All relevant user transaction records, both domestic and foreign: five years following the transaction date.
Information may be kept on file for a long time in the following situations: o in the event that Salter Technologies Private Limited is required to conduct an investigation under law or as part of a requirement before courts, tribunals, forums, commissions, etc.; and o in order to improve or improvise the company's products or services.
By utilizing industry-standard encryption algorithms and access controls, we make sure that user data is adequately restricted. In addition, we have a proactive incident response posture and a strong incident management system in place.

6. DISCLAIMER OF YOUR PERSONAL INFORMATION

You accept and acknowledge that we may gather, compile, and share any information about you with third parties only in order to provide the Services to you (that is, in connection with loan applications and your loan journey), whether or not you directly provide it to us (via the Services or otherwise). This includes but is not limited to personal correspondence like emails, instructions from you, etc.
This may include but not be limited to Lending Partners (as defined in the Terms), storage providers, data analytics providers, consultants, lawyers, and auditors. We may also share this information with our group & affiliate companies with the above mentioned purposes. We might not be able to carry out our responsibilities under the agreement we have with you or are attempting to enter into with you if you refuse to give consent for us to share such data. We might not be able to offer you the Services in this situation.
You understand and agree that by using our services and making an account on the Platform, you give us, our affiliates, and associate partners permission to get in touch with you by phone, email, or other means. This is to make sure you are aware of every feature available on the Services.
You accept and acknowledge that we may share data if we are mandated to do so by law, a court of law, a government agency, or another authority. These disclosures are provided in good faith with the belief that doing so is reasonably required to enforce the Terms, this Policy, or to comply with any applicable laws and regulations.
In the case of a merger, sale, reorganization, amalgamation, joint ventures, assignment, restructuring of business, or transfer or disposition of all or any portion of Our Group Companies, Affiliates, and Subsidiary Companies, as well as Us, may, in accordance with applicable laws, share/transfer/assign all of Your Personal Information and other information with any other business entity(ies).

7. ACCESS AND UPDATING YOUR PERSONAL DATA

By providing us with personal information, you hereby guarantee that it is true, accurate, and up to date. Subject to any legal requirements, we try our best to give you the option to review and correct incomplete or inaccurate data when you use our services. We will confirm that the updated personal information you gave us is accurate.

8. DATA SECURITY

In accordance with applicable laws, Our Platform has reasonable security measures and safeguards in place to protect Your privacy and Personal Information from loss, misuse, unauthorized access, disclosure, destruction, and alteration. Furthermore, We provide the use of a secure server anytime You access Your account on the Platform or any related information. However, we are unable to guarantee that Your Personal Information and/or other Non-Personal Information provided for using the Services or accessing the Platform won't be accessed, disclosed, altered, or destroyed by a breach of any of Our security measures and safeguards, nor can we guarantee the security of any information You transmit to the Company.
It is further made clear that You have a responsibility to take reasonable managerial, technical, and physical precautions to maintain the integrity and security of Your data, which includes but is not limited to Your Personal Information, whenever You access and/or use the Platform (directly or indirectly).
Encryption technology will protect payment information while it is transmitted over the Platform. In order to handle your payment-related information and process payments, you hereby give your explicit consent to the sharing of Your information with third-party service providers, including payment gateways. We take various steps and measures to protect the security of your information from misuse, loss, unauthorized access, modification or disclosure. We use the latest secure server layers encryption and access control on our systems. Please do not share your Account’s login, password and OTP details with anybody.
Even though We take reasonable security precautions to protect Your Personal Information on all of our digital platforms, security risks could still occur due to uncontrollable factors like hacking, virus distribution, natural disasters, firewall breaches, etc. Please be aware that the precautions listed above do not provide complete protection for personal data. In the event that Your information is disclosed as a result of transmission errors, unauthorized third-party access, or other events outside of the Company's control, the Company disclaims all liability and responsibility. You have a significant responsibility to protect the privacy of Your personal data. You agree not to disclose to third parties Your Personal Information or any other account security information.

Regarding Your use of the Platform that We control and Our Services, the Company has taken appropriate steps to safeguard Your right to privacy. However, if any third parties outside of Our control disclose Your personal information without authorization or in violation of the law, We will not be held responsible.

9. THIRD–PARTY WEBSITES

Links from our platform to other third-party platforms (also known as "Third-Party Sites") may allow those platforms to obtain Your Personal Information, such as your IP address, operating system, or browser specifications. The security of said information, the Third-Party Sites' privacy policies, or their content are not under the Company's control. Furthermore, the Company hereby clarifies that the Platform has no control over how these Third-Party Sites use cookies. You may also come across "cookies" or other similar devices on specific pages of the Third-Party Sites. You may be subject to the privacy policies of these third-party service providers and Third-Party Sites, which may regulate how long these parties keep and store Your information.
This Privacy Policy does not govern any information provided to, stored on, or used by these third-party providers and Third-Party Sites. We recommend that when You enter a Third-Party Site, You review the Third Party Site’s privacy policy as it relates to safeguarding of Your information. Ads that You see on the Platform are served by third-party advertising companies on our behalf. To deliver advertisements about products and services that may interest You, these companies may use information (but not Your name, address, email address, or phone number) about Your visits to the Platform and Third-Party Sites. You understand and agree that We are not responsible for any content posted by Third Party Sites or displayed in search results.

10. COOKIES

Cookies are little files of data that are kept on your system. To set you apart from other Service users and to store your preferences, we employ cookies and other tracking technologies. This enables us to better serve you and make sure you have a positive experience using our services.
Through the use of data collection tools like "cookies" on specific Platform pages, we obtain and retain Non-Personal Information for the purposes of assisting with and analyzing Our web page flow, monitoring User Trends, calculating the effectiveness of Our Promotions, and fostering Safety and Trust. We provide extra features on the Platform that can only be accessed by using "cookies." We add both transient and permanent cookies to Your computer’s hard drive.
Additionally, through the use of cookies, You can enter Your password less frequently while using the Platform. The majority of cookies are classified as "session cookies," which means that when a session ends, Your hard drive will automatically erase them. If your browser allows, you can always refuse Our cookies. However, if you do so, you might not be able to use some of the Platform's features or Services, or you might have to enter your password again each time you log in or visit the Platform during a session.
Cookies and other tracking technologies will not be used to collect Personal Data; however, they may be linked to it if you have previously submitted Personal Data.

11. ACCESSING & UPDATING YOUR INFORMATION

At any point of time You can choose to edit/modify or delete/withdraw any Personal Information shared for use of the Platform. Please note that deleting or withdrawing information may affect the Services we provide to you. You can edit/modify or delete Your information by writing to help@larkfinserv.com

12. YOUR CONSENT TO PRIVACY POLICY

By visiting the Platform or setting up/creating an account on the Platform for availing the Services on the Platform at such time, You signify Your acceptance to the provisions of the Privacy Policy.
At any time, you have the option to revoke the consent you have given here. Such a consent withdrawal must be submitted in writing to help@larkfinserv.com. We ask that you refrain from using the Platform and/or its services in the event that You do not give consent, or if You later withdraw Your consent. We also reserve the right to refuse to offer You any services via the Platform. In the event of such a situation, the Company may destroy Your information—whether personal or not—or de-identify it in order to make it anonymous and unrelated to You.

13. CHANGES TO PRIVACY POLICY

We reserve the unconditional right to change, modify, add, or remove portions of this Privacy Policy at any time, without specifically notifying You of such changes. However, We may, at Our sole discretion, provide You push notifications or such other form(s) of notice as We deem necessary to keep You updated about this Privacy Policy. Any changes or updates will be effective immediately. You should review this Privacy Policy regularly for changes. Your continued usage of the Platform shall signify Your consent to such changes and agreement to be legally bound by the same.

14. GOVERNING LAW & JURISDICTION

This policy will be governed by and construed in accordance with the laws of India and subjected to the exclusive jurisdiction of Courts of Delhi.

15. GRIEVANCE OFFICER

LARK aims to provide the best customer service through its Platform. We value customer-relationship and strive to offer an efficient and robust grievance redressal mechanism.
If you have any questions or concerns regarding the Platform, please feel free to contact us.
Customer Service Team (Level 1): You can reach us for any query/complaint by writing to us at help@larkfinserv.com .

Grievance Team (Level 2): If the Complaint/Grievance is not redressed by the Customer Service Centre within 7 working days, the customer shall approach the Digital Lending Grievance Redressal Officer (GRO) of the Company at below details:

Name of Grievance officer	Apoorva Paliwal
Designation	Manager
Address	44 Backary Portion 2nd, Floor, Regal Building, Connaught Place, New Delhi - 110001
Phone Number	+91 7836005500
Email Id:	grievance.officer@larkfinserv.com