TRIUMPH TECHNOLOGY SERVICES PRIVATE LIMITED, whose registered office is situated at Mumbai, Maharashtra, India (hereinafter shall be referred to as "dili" or "Company" or "us" or "we" are the owner of the mobile application by the name dili ("App") and website at www.dilinow.com ("Website") (App and Website are hereinafter together referred to as the "Platform"). As a user ("User" or "You") of the Platform, You understand that Platform provides access between multiple Users in the form of consumers, financial institutions, data partners and other partners lenders, borrowers, service providers etc. with a view to facilitate lending and borrowing activities, including facilitating taking of loans by You, providing other financial products etc., collectively referred to as Product or Products, between the Users. List of our lending partners is provided at Schedule 1 herewith.
If you do not agree to this Policy or any part thereof, please do not use/ access/ download or install the Platform or any part thereof.
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 unauthorized 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 customized user experience to you.
COLLECTION OF CONTACT INFORMATION
As a part of our loan journey, we require references from the Loan applicant. In this regard, during filing the form on our App, we collect and monitor your contact information which includes name, phone number, account type, contact last modified, favourites and other optional data like relationship and structural address to enable you to autofill the data during the loan application process. This basic minimal information is required for the purposes of risk analysis, enabling us to detect credible references, assess your risk profile and to determine your loan eligibility and the same is stored in servers located within India.
We require camera access to scan and capture the required KYC documents thereby allowing us to auto‐fill relevant fields. As a part of our KYC journey, we require access to your camera to enable you to initiate your KYC process. This permission allows us, our partner NBFC’s and Banks (Loantap - https://loantap.in/) or their authorised agents to perform your Video KYC while also taking screenshots of your original Officially Verified Documents that you present during your Video KYC journey. Video KYC enables you to complete your KYC digitally, smoothly and efficiently. Your video shall be recorded and retained where required for regulatory purpose along with screenshots of original Official Verified Documents.
We require microphone permissions to enable a two‐way communication between their authorised agent (our partner NBFC’s and Banks) and you for the purpose of performing and completing your Video KYC. Your audio shall be recorded where required for regulatory purposes.
COLLECTION OF OTHER NON‐PERSONAL INFORMATION
If you choose to make a purchase through the Platform, we collect information about your buying behaviour. We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.
If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Website, we collect such information into a file specific to you.
COLLECTION OF BUREAU DATA
We will process the credit bureau data that you provide us access to during the journey on our platform and share this with our affiliates and partners in order to compute your credit eligibility score.
COLLECTION OF BANK STATEMENT
We will process your banking transaction data that you provide us access to during the journey on our platform and share this with our affiliates and partners in order to compute your credit eligibility score.
USE AND DISCLOSURE OF YOUR PERSONAL AND OTHER INFORMATION
We use the information to: a. resolve disputes; b. troubleshoot problems; c. help promote a safe service; d. analytical analysis; e. marketing purposes; f. measure consumer interest and satisfaction in our products and services; g. inform you about online and offline offers, products, services, and updates; h. customize your experience; i. detect and protect us against suspicious or illegal activity, fraud and other criminal activity; j. enforce our terms and conditions; k. improvement of our services and as otherwise described to you at the time of collection In our efforts to continually improve our product and service offerings, we collect and analyze demographic and profile data about our users' activity on our Platform.
PURPOSE OF COLLECTING INFORMATION
The intended purpose of collecting information provided by you is to: a. establish identity and verify the same; b. to complete your Video KYC/ digital KYC; c. monitor, improve and administer our Platform; d. provide our service i.e. perform credit profiling for the purpose of facilitating loans to You. e. design and offer customized products and services offered by our third party financial partners; f. analyse how the Platform is used, diagnose service or technical problems and maintain security; g. send communications notifications, information regarding the products or services requested by You or process queries and applications that You have made on the Platform; h. manage Our relationship with You and inform You about other products or services We think You might find of some use; i. conduct data analysis in order to improve the Services / Products provided to the User; j. use the User information in order to comply with country laws and regulations; k. conduct KYC for our third party lending partners based on the information shared by the User; l. use the User information in other ways permitted by law to enable You to take financial services from our lending partners.
We will use and retain the information for such periods as necessary to provide You the Services on the Platform, to comply with our legal obligations, to resolve disputes, and enforce our agreements.
DISCLOSURE TO THIRD PARTIES
We may share your information with our third party partners including our regulated financial partners for provision of Services on the Website/ App. We will share Your information with third parties, including credit bureaus only in such manner as described below:
We disclose and share Your information with the financial service providers, Credit bureaus, bank statement analysis companies, banks or NBFCs and our third party partners for facilitation of a loan or facility or line of credit or purchase of a product;
In case we use or disclose your information for any purpose not specified above, we will take your explicit consent.
ACCESSING YOUR INFORMATION / CONTACTING US
At any point of time Users 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. In case of modification of Personal Information, Users will be required to furnish supporting documents relating to change in Personal Information for the purpose of verification by the Company.
YOUR PRIVACY CONTROLS
You have certain choices regarding the information we collect and how it is used: a. Device‐level settings: Your device may have controls that determine what information we collect. For example, you can modify permissions on your device for access to Camera or Audio permissions. b. You can also request to remove content from our servers based on applicable law by writing to us at email@example.com.
b. You have the right 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
c. No biometric data is stored/ collected in the systems of the platform, unless allowed under extant statutory guidelines
The Platform intends to protect your information and to maintain its accuracy as confirmed by you. We implement reasonable physical, administrative and technical safeguards to help us protect your information from unauthorized access, use and disclosure. For example, we encrypt all information when we transmit over the internet. We also require that our registered third party service providers protect such information from unauthorized access, use and disclosure.
Our Platform has stringent security measures in place to protect the loss, misuse and alteration of the information under control. We endeavour to safeguard and ensure the security of the information provided by you. We use Secure Sockets Layers (SSL) based encryption, for the transmission of the information, which is currently the required level of encryption in India as per applicable law.
We blend security at multiple steps within our products with the state of the art technology to ensure our systems maintain strong security measures and the overall data and privacy security design allow us to defend our systems ranging from low hanging issue up to sophisticated attacks.
The Platform complies with various technology standards/ requirements on cybersecurity stipulated by RBI and other agencies, or as may be specified from time to time, for undertaking / facilitating digital lending
We or our affiliates maintain your information on servers located in India. Data protection laws vary among countries, with some providing more protection than others. We also comply with certain legal frameworks relating to the transfer of data as mentioned and required under the Information Technology Act, 2000 of India and rules made thereunder.
When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.
LINKS TO OTHER SITES
Our Platform may have links to other websites that may collect information about you. We are not responsible for the privacy practices or the content of those linked websites. With this Policy we’re only addressing the disclosure and use of data collected by us. If You visit any websites through the links on the Website, please ensure You go through the privacy policies of each of those websites. Their data collection practices, and their policies might be different from this Policy and We do not have control over any of their policies neither do we have any liability in this regard.
For any queries or complaints contact us at: Phone: +91 9619277859 Email: firstname.lastname@example.org
Schedule 1: List of Lending Partners LoanTap Credit Products Private Limited (https://loantap.in/)