1.1. HTPL respectsthe belief that users place in the Account and insists upon the highest standards for making the transactions fully secure and maintaining the privacy of their personal information.
1.3. If case where user does not wish/wants HTPL to collect, disclose, share and use users’ information, including but not limited to any personal information (as defined below), user may choose not to register for an account or terminate their account with HTPL in accordance with the applicable Terms and Conditions available at the App/web.
2.1. As for creation of an account and to use the services provided by HTPL, users shall be required to register themselves on HTPL App/web, and as for registration, HTPL may require users to provide certain sensitive personal information, which includes all information that are required to identify the user as an Account holder of HTPL (“Personal Information”). User may provide such Personal Information at their sole discretion, however in case user wishes to avail HTPL services, it is mandatory for user to provide their Personal Information to HTPL which may include the following:
2.1.1. User full name, address, email address, telephone number, date of birth, photograph along with their supporting KYC documents. One time access for user’s camera, microphone, location and mobile device and store such information only for the purpose of onboarding or KYC requirements of HTPL with user’s explicit consent in accordance with the Digital Lending guidelines issued by RBI and as amended from time to time.
2.1.2. Bank account details i.e., Bank name, Account holder name, account number and IFS code, as required by HTPL.
The information as stated above in point no. 2.1.2 may be collected, used and processed by HTPL directly, or by an authorized and industry approved service providers engaged with HTPL for the purpose of providing the payment gateway services on HTPL App/web. Where any such information is collected, used and processed by an authorized and industry approved service providers, user hereby agree to the transfer their Personal Information to HTPL and our affiliates.
2.2. In addition to the Personal Information, certain information may also be collected from users at times which may include:
2.2.1. Information collected through “Cookies”; Please refer to Section 3.2 for more information on Cookies.
2.2.2. Frequency of users visit to HTPL app/web, including but not limited to HTPL logs and other communication data, whether this is required for users own purposes or otherwise, and the resources that user access whilst visiting HTPL App/web.
2.2.3. IP address of user server from where the App/web is being accessed, the type of browser and the operating system the users’ system has, the referring source which may have sent user to the app/web.
2.2.4. The duration of user stay on HTPL App/web is also stored in the session along with the date and time of users’ access.
2.3. Whenever User, uses the app/web, HTPL’s servers (which may be hosted by an authorized and industry approved service providers service provider) may collect information directly or indirectly, and automatically, about users’ activities on the App/web by way of cookies, HTPL beacons or HTPL analytics. This anonymous information is maintained distinctly and is not linked to the Personal Information user submit to HTPL and shall not be used to identify user Account.
2.3.1. HTPL beacons are graphic image files embedded in a HTPL page that provides information from the user’s browser. This allows HTPL to monitor and ascertain the number of users of the App/web, and other purposes as may be required by HTPL. With both cookies and web beacon technology, the information that HTPL collects is anonymous and not personally identifiable. It does not contain user’s name, address, telephone number, or email address.
2.3.2. HTPL analytics are services provided by authorized and industry approved service providers parties in connection with a HTPL app/web. HTPL may use such services to find usability problems to make the App/web user friendly. These services do not collect information that has not been voluntarily provided by user.
2.5. The Personal Information as aforesaid is essential to provide the services offered by HTPL. User shall ensure that all the information provided to HTPL is true, correct, complete and genuine in all respects. User shall always have access to the information provided and shall ensure to amend/correct/update such information at the earliest using the App/web or by contacting HTPL on customer care number. HTPL shall not be responsible for the authenticity of the Personal Information provided by user to HTPL. In no event, HTPL shall be liable for any losses that user may incur due to the inaccurate or deficient information or Personal Information provided HTPL. User will however be fully liable to HTPL and the authorities for any inaccurate/ incomplete data or information provided by HTPL.
3.1. The information collected from user shall be used for the following purposes only:
(a) To operate and administer user account and to continually improve HTPL service offerings.
(b) To make and receive payments for transactions undertaken by user using the App/web, customer/merchant verification,
(c) to ease user’s use of the App/web.
(d) to respond to user inquiries, complaints or fulfill users’ requests for information about the various services.
(e) to provide the information about HTPL's products/services and to send user the information, materials, and offers from HTPL, even if users have registered under DND or DNC or NCPR services.
(f) to send users the important information about any changes made in terms and conditions, policies and/or other administrative information to HTPL's
(g) to send users any surveys and marketing communications that HTPL believes may be of interest to users.
(h) to help users address their problems with the App/web including addressing any technical problems.
(i) to conduct internal reviews and data analysis for the App/web.
(j) to provide user information for scrutiny to any statutory, regulatory or any other governmental authority or any other agency as advised by government or any judicial body or as may be required by law for the time being in force.
(k) to manage disputes that may arise because of provision of services to User.
(l) to detect and protect HTPL against error, fraud, phishing, unauthorized transactions, and other criminal and illegal activity.
(m) HTPL identify and use HTPL IP address to help diagnose problems with HTPL server, and to administer HTPL App/web. User IP address is also used to help identify User and to gather broad demographic information.
(n) to improve HTPL internal customer/merchant training.
(o) to comply with applicable laws, including requirements under any financial services regulation, such as retention of financial and transaction information.
(p) to conduct financial and identity checks; fraud prevention checks; anti money laundering and credit checks.
(q) to enhance security of HTPL App/web; and
(r) to create statistical information, statistical analysis, credit scoring, or for any other purpose that will help in providing user with optimal and high-quality services.
3.2.1 A "cookie" is a small piece of information stored by a HTPL server on a HTPL browser so it can be later read back from that browser. Cookies are useful for enabling the browser to remember information specific to a given User. These cookies do not contain any of User’s personally identifiable information. However, user may choose to disable the Cookies using the settings in his computer system, but in that case the user may face certain difficulties to use the full functionality of the App/web.
3.2.2 Cookies may be used for the following purposes:
(a) To customize user experience on HTPL app/web.
(b) To obtain information regarding use of the App/web and assess which pages user visit the most to provide user with services that may be of interest to services.
(c) To obtain information regarding user IP address, location and other demographic information such as age range and gender to ascertain Users internet behavior, in accordance with applicable laws.
(d) To assist in complying with regulatory obligations such as antifraud and anti-money laundering obligations.
(e) To allow HTPL to provide user with personalized services by remembering the choices made by user with respect to language user prefer, geographical location where user is etc. in accordance with applicable laws.
(f) When user visit authorized and industry approved service providers HTPL app/web s from HTPL App/web, cookies embedded in such authorized and industry approved service providers content may be downloaded onto user device. HTPL do not control such authorized and industry approved service providers cookies and the same are governed by the terms and conditions of such authorized and industry approved service providers parties. Please read the terms and conditions governing such authorized and industry approved service providers HTPL app/web s for more information on the same.
4.1. After termination of user account, HTPL shall destroy all the data collected from user, except the records and the data pertaining to the transactions undertaken using HTPL services on the App/web, and where required to ensure compliance with applicable laws. Please note that under the applicable laws, HTPL may maintain record of the transactions with HTPL, including personal data such as username, contact details, etc. Subject to the above, HTPL will delete all other Personal Information including the banking details (debit/credit card), and passwords of user when user account is terminated. The termination of an account is defined wherein consumer has no dues, uninstalled the APP and has no interaction with the service provider for more then 90 days.
4.2. Please note that HTPL will not require user to disclose users personal, financial or security details vide email or other communication, except through the App/web, unless otherwise explicitly specified by HTPL. If user receive any email/ phone call/ SMS or other communication requesting user to share their security/financial information, please do not respond to such requests, and delete such requests. Please however forward such requests to firstname.lastname@example.org for notifying HTPL of the same, prior to deletion of such requests.
4.3. “Phishing” is an attempt to steal personal details and financial account details from a HTPL app/web user. Such “Phishers” use fake emails to lead users to counterfeit HTPL app/web s where the user is tricked into entering their personal details such as credit card numbers, passwords, PIN etc. Users are abstained from providing their details on such HTPL app/web and immediately report such requests to HTPL at email@example.com. HTPL shall not be held responsible for any loss, damage etc. caused to users by responding to such emails and sharing information with authorized and industry approved service providers parties specified under Sections 4.2 and 4.3.
5.3. However, HTPL may disclose the personal data, or any other information collected from user to any statutory, lawful enforcement body, regulatory body or court if HTPL is under legal obligation if required by law/authority to disclose or share user personal data or any other information collected from user or in relation to user transactions on the App/web.
5.4. To protect HTPL financial interests and avoid money laundering or fraudulent activities, HTPL may, if HTPL deem necessary, share user information, including user Account details, financial and transactional history with banks, payment facilitator partners, identity verification service providers, and credit reference agencies and other agencies to identify and verify Users and limit exposure to criminal activity and financial risk. When conducting the audit/checks, the relevant authorized and industry approved service providers parties may retain information regarding HTPL query and user information and may share this information with other fraud prevention agencies.
5.6. To prevent money laundering activities and comply with applicable regulations, HTPL may report suspicious transactions to law enforcement agencies. User hereby authorize HTPL the right to share user information with such law enforcement agencies in the event of any activity that may seem suspicious in HTPL sole discretion. In the event HTPL notice any suspicious activity on the App/web, HTPL may, without prior intimation to user:
(i) report such instance to the law enforcement agency and share all relevant information that may be required for investigation.
(ii) suspend user Account during the period of investigation; and/or
(iii) block user use of the Account.
7.1. HTPL strive to ensure the security, integrity and privacy of users’ Personal Information from unauthorized access or unauthorized alteration, disclosure or destruction. HTPL adopt adequate measures to prevent unauthorized access to user Personal Information.
6.2. HTPL reserve the right to conduct a security review at any time to verify user identity/details. User consents to provide HTPL all the information that HTPL request for the security review. If user fail to comply with any security request, HTPL reserve the right to terminate /suspend access to/use of user Account, and/or prohibit user access to the App/web.
6.3. HTPL are not liable and cannot be held liable for any breach of security or for any actions of any authorized and industry approved service providers parties that receive user Personal Information.
7.3. HTPL shall not be responsible for any loss, damage, claim or expense caused because of You accessing these authorized and industry approved service providers app/web s and features.
One time access/ permissions are being sought by the service provider/digital platform/APP, from the consumer at the event of downloading the application, registration or requesting for loan.
Camera Access – to capture the individual image, check the liveliness and authentication of the applicant. The incident may be termed as “Selfie”
Media Access – to affix the captured consumer image with the profile created by individual self on the “APP”, to edit/ update the profile image later only if the customer wish to do so.
SMS Access –to read otp or any other number generated to validate and authenticate the user.
Location – for the purpose of on-boarding/ KYC requirements only, with the explicit consent of the user.
User can always choose not to provide information, which is not mandatory in nature but in case the information required is mandatory and user does not wish to provide the requisite information, then user will not be able to access the app/web or the service fully and HTPL shall have the option to stop providing the services for which the information was sought. Users will not be eligible for a refund of any fees paid for any service in such event and agrees that HTPL shall not be liable to user for the same in any manner whatsoever.
10.1 HTPL may contact users via the App/web, e-mail address and phone number as provided by user. Users may also receive system-generated transactional e-mails such as confirmations, notification of receipt of payments, notification of password changes, OTP for verification of payments etc.
10.2. User hereby gives their consent to HTPL to receive communications through the App/web, registered phone number and/or e-mail id.
Grievance Officer: Mr. Gajendra Singh
Email Address: firstname.lastname@example.org
Phone Number: 0120-6917474
HTPL Contact information:
Email Address: email@example.com
Phone Number: 0120-6917474