PRIVACY POLICY
Effective Date: 28 January 2019
Hero FinCorp Limited, a company incorporated under the provisions of Companies Act, 1956, a Non Banking
Financial Company registered with Reserve Bank of India and having its registered office at 34, Community
Centre,
Basant Lok, Vasant Vihar, New Delhi-110057, (hereinafter referred to as "HFCL" or "we" or
"us"), recognizes the
expectations of its customers with regard to privacy, confidentiality and security of their personal
information that
resides with HFCL. Keeping personal information of customers secure and using it solely for activities related
to HFCL
and preventing any misuse thereof is a top priority of HFCL. HFCL has adopted the privacy policy aimed at
protecting
the personal information entrusted and disclosed by the customers [“the Policy” or “this Policy”].
THIS POLICY DESCRIBES OUR POLICIES AND PROCEDURES FOR COLLECTION, USE, STORAGE, PROCESSING, DISCLOSURE AND
PROTECTION OF ANY INFORMATION, INCLUDING, BUT NOT LIMITED TO, PERSONAL OR BUSINESS INFORMATION PROVIDED BY YOU
AS A USER (hereinafter referred to as “You” “Your” or “User”) WHILE USING THE MOBILE
APPLICATION. USER SHALL MEAN ANY PERSON/ PERSONS, WHO VISITS, USES, DEALS WITH AND/ OR TRANSACTS THROUGH THE
MOBILE APPLICATION.
THIS POLICY CONSTITUTES A LEGAL AGREEMENT BETWEEN YOU, AS THE USER OF THE MOBILE APPLICATION, AND HFCL, AS THE
OWNER OF THE MOBILE APPLICATION. YOU MUST BE A NATURAL PERSON, CITIZEN OF INDIA, WHO IS ATLEAST 18 YEARS OF
AGE.
BY VISITING/ ACCESSING THE MOBILE APPLICATION, YOU ARE CONSENTING TO USE AND SHARE YOUR PERSONAL INFORMATION IN
ACCORDANCE WITH THIS POLICY. THIS POLICY DOES NOT APPLY TO THIRD-PARTY WEBSITES/ APPLICATIONS THAT ARE
CONNECTED VIA LINKS TO THE WEBSITE. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, PLEASE DO
NOT PROCEED FURTHER TO USE/ACCESS THIS MOBILE APPLICATION.
YOUR USE OF THE MOBILE APPLICATION WILL BE GOVERNED BY THIS POLICY TOGETHER WITH ALL POLICIES, NOTICES,
GUIDELINES, DISCLAIMERS THAT ARE PUBLISHED AND SHARED WITH YOU FROM TIME TO TIME WHICH ARE INCORPORATED HEREIN
BY WAY OF REFERENCE INCLUDING BUT NOT
LIMITED TO OUR TERMS OF USE AND SUCH OTHER TERMS AS MAY BE APPLICABLE TO YOU IN YOUR CAPACITY AS A USER
OF THE MOBILE APPLICATION. THIS POLICY SHALL BE ENFORCEABLE AGAINST YOU IN THE SAME MANNER AS ANY OTHER WRITTEN
AGREEMENT.
WE MAY UPDATE THIS POLICY FROM TIME TO TIME. YOU MUST PERIODICALLY REVIEW THE POLICY FOR
THE LATEST INFORMATION ON OUR PRIVACY PRACTICES.
- General
This Policy applies regardless of whether you use a computer, mobile phone, tablet, or any other media
or electronic resource to access our Services. It is important that you read the Policy carefully
because anytime you
use our Services, you consent to the practices/ policies that we have set out in this Policy.
- Personal Information/Information we collect
HFCL asks for and uses your personal information and is committed to keeping this information secure.
You hereby
irrevocably and unconditionally grant consent to HFCL to share, receive, record, store, and process
your Personal
Information as well as other information relating to your transaction that also may be Personal
Information, including
the date, amount, and location of the transaction. You must keep your Personal Information up to date,
and intimate
HFCL forthwith of any change in Personal Information.
HFCL has expended considerable time, effort, and resources, and implemented technical and
organizational
measures, to maintain the security of your Personal Information. However, HFCL cannot and does not
guarantee that
your Personal Information is impervious to all breaches of security through interception, hacking, or
other means.
HFCL collect the following types of information:
Information you provide us directly
- Identification Information: Your name, email address, phone number, mobile number,
signature and photograph,
any other contact details, government or other identity documents, date of birth, gender,
Aadhaar number; your other relevant KYC documents as required by HFCL.
- Bank account or other payment instrument details;
- Other: Other historical, contact, and demographic information
- Any other detail which may be required by us for providing Services.
Information We Collect from Your Use of our Services
Information that We may collect from Your use of Our Services, such as:
- SMS Information: We read SMS to retrieve OTP sent by HFCL during login or transaction
related authentication.
- Location Information: Through our applications, we collect information about the
location of your device.
- Media Information: We facilitate users to capture / upload relevant documents as may be
required to be uploaded during user account management or transaction order placement.
- Device Information: We collect specific information about your device when you access
our Services, including your storage, hardware model, operating system and version, unique
device identifier, mobile network information, and information about the device’s interaction
with our services.
- Use Information: We collect information about how you use our Services, including your
access time and Internet Protocol (“IP”) address.
Please refer our SDK policy below for the data that we collect from your device.
Information We Collect from Other Sources
We also collect information about you from third parties, including third-party
verification services, credit bureaus and publicly available sources. In some circumstances, where
lawful, this information may include your government-issued identification number. This includes,
without limitation, the receipt and exchange of account or credit-related information with any
credit reporting agency or credit bureau, where lawful, and any person or corporation with whom you
have had, currently have, or may have a financial relationship, including without limitation past,
present, and future places of employment and personal reporting agencies.
- SDK Policy
Hero FinCorp Customer app, powered by Hero FinCorp has a link to a registered third-party SDK which
collects data on our behalf and data is stored to a secured server to perform a credit risk
assessment. If you use the Hero FinCorp Customer app with agree option, we may use third party
SDK’s ( Hyperverge etc.), cookies and other similar tracking technologies to improve your app usage
experience. We ensure that our third-party service provider takes extensive security measures in
order to protect your information against loss, misuse, or alteration of the data. Our third-party
service provider employs separation of environments and segregation of duties and have strict
role-based access control on a documented, authorized, need- to-use basis. The stored data is
protected and stored by application-level encryption. They enforce key management services to limit
access to data. Furthermore, our registered third-party service provider provides hosting security
– they use industry- leading anti-virus, anti-malware, intrusion prevention systems, intrusion
detection systems, file integrity monitoring, and application control solutions.
Our Hero FinCorp Customer app may collect information with your consent from your mobile device
like device location, device information (including storage, model, installed apps, Wi-Fi, mobile
network) transactional and promotional SMS, communication information including contacts to provide
customized offerings. Below information may be collected through the Android app permissions which
you have granted us. To this effect, explicit consent screen and the usage of data will be
explained on the interface as well.
The data so collected via SDK’s will be used to operate, improve the user’s app experience as well
as to send customized marketing & promotional communication and personalized offers
Details for each permission is elaborated as below:
- Location: Hero FinCorp Customer app collects information about the location of your
device for risk assessment.
- Storage: Hero FinCorp Customer app will require you to take a selfie to complete the
loan application process. While raising any support queries you can take screenshots; We
access them to provide better customer support. We need storage permission to access this
content.
The above data points collected, shared, and transmitted by our third-party SDK's ( Hyperverge) are
used for building comprehensive credit risk assessment and credit profile. This information shall
be securely shared with our providers, affiliates, and partners.
Information Sharing
Hero FinCorp Customer app will not sell or rent your Information to anyone, for any reason, at
any time. However, we will be sharing your Information with our financial partners, affiliates
and business partners, and the User hereby consents to the same. We will take reasonable steps
to ensure that these third-party service providers are obligated to protect your information and
are also subject to appropriate confidentiality/non-disclosure obligations and they comply with
the applicable provisions of the data protection laws
- Use of Personal Information
We use personal information to provide you with personal loan you explicitly requested for, to
resolve disputes,
troubleshoot concerns, help promote safe services, assess your interest in our services, inform you
about offers,
products, services, updates, customize your experience, detect and protect us against errors, fraud
and other
criminal activity, enforce our terms and conditions, etc. We may also use your personal information
to send you
offers regarding various services/facilities which HFCL or its group companies may, from time to
time, launch.
We may occasionally ask you to complete optional online surveys. These surveys may ask you for
contact
information and demographic information (like zip code, age, gender, etc.). We use this data to
customize your
experience at HFCL. We also may use information about you to measure, customize, and enhance our
Services,
including the design, content, and functionality of our applications and websites, or to track and
analyze trends
and usage relating to our Services.
Further, HFCL or any third party, as may be authorized by HFCL may use information about you to
provide,
maintain, and improve our Services, such as:
- detect and prevent fraud;
- develop and test new products and features;
- verify information that you have provided;
- to form a view of you as an individual and to identify, develop or improve products, that
may be of interest to you;
- delivering the information and support you request, including technical notices, security
alerts, and support and
administrative messages;
- diagnose or fix technology problems
- conduct statistical and market analysis; and
- satisfy any other legitimate business purposes, including handling any complaints and
retaining information as
necessary to meet our obligations under applicable laws and regulations.
- to get in touch with you when necessary and contact you by email, SMS, letter, telephone
or in any other way about
our products and services;
- to provide you with the services that might be required by you;
- to take up and investigate any complaints/claims/disputes,
- to process your financial and non-financial transaction requests,
- to respond to your queries and feedback submitted by you;
- to find adequate references for your loan application;
- to give you customized offers as per your location;
- to conduct data analysis in order to serve You better and provide Services;
- carry out, monitor and analyze our business, carry out market research, business, and
statistical analysis and also
direct our efforts for product improvement;
- to maintain records under applicable law or a may apply to pursuant to agreements
executed by us.
- to fulfil the requirements of applicable laws / regulations and / or court orders /
regulatory directives received by us.
- For any other purpose as may be decided by HFCL.
HFCL or any third party, as may be authorized by HFCL, may use information about you to
improve, personalize
and facilitate your use of our Services. For example, we may associate certain information with
your new account,
such as information about other loan applications you have with HFCL or any other financial
institutions, and
prior transactions you made using our services and the usage of our products.
Further, HFCL or any third party, as may be authorized by HFCL may use information about
you:
- To enforce the terms of our General Terms or other applicable agreements or policies;
- To verify your identity (e.g., some of the government-issued identification numbers we
collect are used for this
purpose);
- To investigate, detect, and prevent fraud, security breaches, and other potentially
prohibited or illegal activities;
- To comply with any applicable law, regulation, legal process, or governmental request;
- For any other purpose disclosed to you relating to our Services.
- Storage of Information and Disclosure
Storage
We store and process your personal information on HeroKU platform( Hosted on AWS) (with US
Region) cloud servers and other cloud
service providers. Some of the safeguards we use are firewalls and data encryption using SSL,
and information access
authorization controls. We use reasonable safeguards to preserve the integrity and security of
your information
against loss, theft, unauthorised access, disclosure, reproduction, use or amendment. To achieve
the same, we use
reasonable security practices and procedures as mandated under applicable laws for the
protection of your
information. Information you provide to us may be stored on our secure servers located within or
outside India.
However, you understand and accept that there’s no guarantee that data transmission over
the Internet will be
completely secure and that any information that you transmit to us is at your own risk. We
assume no liability for
any disclosure of information due to errors in transmission, unauthorized third party access to
our mobile
application and data bases or other acts of third parties, or acts or omissions beyond our
reasonable control and you
shall not be entitled to hold HFCL responsible for any breach of security.
- Disclosure of Information
The Information provided by you may be disclosed to:
- RBI, SEBI, CIBIL, Credit Bureaus, Credit Rating Agencies, Databanks, KYC Registration
Agencies (KRAs) and
other such agencies, solely for the purpose of processing your transaction requests for
serving you better;
- Another business entity to carry out any business activity or re-organization,
amalgamation, restructuring of business or for any other reason whatsoever;
- Any actual or proposed assignee, transferee, participant or sub-participant of HFCL;
- Any judicial, government or regulatory bodies, statutory authorities, quasi judicial
authorities;
- Any other banks, NBFCs or financial institutions;
- Auditors, professional advisors;
- Any Affiliate, associate, office of HFCL and to their employees;
- Any other third party service providers.
We may share your information with third parties under a confidentiality agreement for provision
of Services which
inter alia restricts such third parties from further disclosing the information unless
such disclosure is for the purpose as detailed under that confidentiality agreement. However, we
are not responsible for any breach of security or for any actions of any third parties that
receive your personal information.
We shall not publish the sensitive personal data or information or disclose it further, without
your consent, for any
purpose other than stated above.
- Retention of Information
HFCL shall not retain or store such information for periods longer than is required for the
purposes except when the
information may lawfully be used or is otherwise required under any other law for the time
being in force.By agreeing to avail the services offered by HFCL, You have agreed to the
collection and use of your Sensitive Personal
Data or Information, as well, by HFCL. You always have the right to refuse or withdraw your
consent to
share/disseminate your Sensitive Personal Data or Information by contacting the customer
care. However, in the
event of your refusal or withdrawal of personal data, you shall not be able to avail any
services of HFCL to the fullest extent.
- Updating Your Information
You may upon written request to update the personal data or information provided by You. HFCL
shall ensure that
any personal information or sensitive personal data or information found to be inaccurate or
deficient shall be
corrected or amended as feasible.
- Cookies
Cookies are small data files that a Website stores on your computer. We will use cookies on
our Website similar to
other lending websites and online marketplace websites. Use of this information helps us
identify you, the User
behaviour, the products that the User browses, in order to make our Website more user
friendly and to be able to
provide you with information relating to Products that may be of interest to you. We might
also use this information
to display advertising from third party companies. Most browsers will permit you to decline
cookies but if you choose
to do this it might affect service on some parts of Our Website.
We might also use other technology to track how you interact with Website and employ
some third party agencies to use the data on our behalf for data analysis to determine your
use and journey on the Website.
- Reasonable Security Practices and Procedures
The security of personal information is a priority and is protected by maintaining physical,
electronic, and procedural
safeguards that meet applicable laws. HFCL shall take reasonable steps and measures to protect
the security of your
personal information from misuse and loss, un-authorized access, modification or disclosure.
HFCL maintains its
security systems to ensure that the personal information of the customer is appropriately
protected and follows the
extant standard encryption norms followed for the transmission of information. HFCL ensures that
its employees and
affiliates respect the confidentiality of any personal information held by HFCL.
However, we do not warrant or represent that your personal information is completely safe from
hackers and other security threats.
- Third-Party Links and Content on our Services
Our Services may link to third-party websites and services that are outside our control.
Further, HFCL, its group
companies, its affiliates, and their directors and employees (“HFCL Group”) accept no liability
and will not be liable
for any loss or damage arising directly or indirectly (including special, incidental or
consequential, punitive, or
exemplary loss, damage or expenses) from your use of any mobile application or any site or
inability to use by any
party, howsoever arising, and including any loss, damage or expense arising from, but not
limited to, any defect,
error, omission, interruption, imperfection, fault, mistake or inaccuracy with any mobile or
online application, its
Contents (material, information, data, money market movements, news items, etc.) or associated
services, or due to
unavailability of any application or any part thereof or any Contents or associated services
even if HFCL Group are
advised of the possibility of such damages, losses or expenses.
- Phishing
“Phishing" usually occurs when users are induced by an individual/entity into divulging
sensitive personal data by
using fraudulent websites and/ or e-mail addresses. In the event You provide information to a
website or respond to
an e-mail which does not belong to Us or is not connected with Us in any manner, You will be a
victim of Phishing.
We do not send e-mails requesting a User for payment information, user name or passwords.
However, We may
verify the user name, password etc. provided by You from time to time.
- Intellectual Property Rights
Please note that HFCL retains all rights (including copyrights, trademarks, patents as well as
any other intellectual
property right) in relation to all information provided on or via this web site (including all
texts, graphics and
logos).
- Consent
You consent to the collection and use of the information you disclose to HFCL in accordance with
this Privacy
Policy, including but not limited to your consent for sharing your information as per this
Privacy Policy.
- Severability and Exclusion
We have taken every effort to ensure that this Policy adheres with the applicable laws. The
invalidity or
unenforceability of any part of this Policy shall not prejudice or affect the validity or
enforceability of the remainder of this Policy. This Policy does not apply to any information
other than the information collected by HFCL through the Mobile Application. This Policy shall
be inapplicable to any unsolicited information You provide Us through this Mobile Application or
through any other means. This includes, but is not limited to, information posted in any public
areas of the Mobile Application. All unsolicited information shall be deemed to be
non-confidential and the Company shall be free to use and/ or disclose such unsolicited
information without any limitations.
- Disclaimer
Kindly note that HFCL does not collect personal information about you unless you use this mobile
application. We
may also receive information about you from third-party social networking services if you are
already connected
with those services. HFCL shall, at all times, ensure to implement reasonable security practices
and procedures
(such as managerial, operational, physical and technical) for the purpose of protection and
safeguarding of your
personal data and information as the same is of vital importance to HFCL. At HFCL, we are
strongly committed to
protecting the personal and financial information that you submit to us. Personal information of
individual users
will not be sold or otherwise transferred to unaffiliated third parties without your approval at
the time of collection.
However, please note that although we take reasonable steps to protect your information, no
website, internet
transmission, computer system or wireless connection is completely secure.
HFCL shall ensure to safeguard the security and confidentiality of any information you share
with us. Any of your
personally identifiable information obtained by us shall not be used or shared other than for
the purposes to which
you consent. However, despite our utmost efforts to protect your personal information, HFCL
cannot warrant the
security of any information you transmit to us through our online services/ applications. By
accepting this Privacy
Policy, you accept that such transmission of your personal information is done at your own
risk.
Your information/inputs/queries as a registered user are required to serve you better and the
same shall not be
shared with anyone without your consent. However, we may disclose your personal data to agents
or contractors of
HFCL and/or its group companies/affiliates to enable processing of transactions or
communications with you “on
need” basis. Your aforesaid information may be further used for assessment and analysis of our
market, customers,
products, and services and to understand the way people use our Services so that we can improve
them and
develop new products and services. However, it shall be on the basis that the agents are
required to keep the
information confidential and will not use the information for any other purpose other than to
carry out the services
they are performing for HFCL and/or its group companies/affiliates.
- Online Surveys
For better understanding the needs and profile of our users we conduct on-line surveys. When we
conduct the
survey, we will try to let you know how we shall use said information at the time of collecting
information from You
on the internet. However, the same is not obligatory on our part. You recognize and understand
that there is no
compulsion on your part to provide us with your personal information and all personal
information provided by You
to us is with your full consent, own will and desire to provide such personal information. You
also understand that
we are under no obligation to verify the source from which the personal information about You is
provided to us and
is deemed to be provided by You.
- Governing Law and Dispute Resolution
This Policy shall be governed by and construed in accordance with the laws of India. The courts
at Delhi, India shall
have exclusive jurisdiction in relation to any disputes arising out of or in connection with
this Policy.
- No Waiver
The rights and remedies available under this Policy may be exercised as often as necessary and
are cumulative and
not exclusive of rights or remedies provided by law. It may be waived only in writing. Delay in
exercising or non-
exercise of any such right or remedy does not constitute a waiver of that right or remedy, or
any other right or
remedy.
- Indemnity
You agree to indemnify, defend and hold harmless HFCL its affiliates and their respective
officers, directors, employees and agents, harmless from and against any claims, demands, loss,
damages, liability, causes of action, losses, proceedings, judgments, or reasonable costs and
expenses of every nature (including reasonable attorney’s fees and expenses) arising out of non
compliance to applicable laws, rules, regulations and notifications as amended from time to
time, provided, act of negligence, misfeasance or fraud on account of breach of any/all of the
terms of this Privacy Policy.
- Contact Us
If You require any information or clarification regarding the use of Your personal information
or this Privacy Policy,
You can contact us at customer.care@herofincorp.com
- Grievance Redressal Mechanism
If You have grievance with respect
to use of Your personal information, please write to Us at
customer.care@herofincorp.com
HFCL has a structured grievance redressal mechanism in practice where all grievances will be
attended as per a defined time schedule as mentioned in grievance Redressal policy available
at https://www.herofincorp.com/sites/default/files/Grievance-Redressal-Policy.pdf