Privacy Policy

Privacy Policy

This Privacy Policy sets out the approach of Agarwal Assignments Private Limited ("AAPL") towards the collection, use, storage, and protection of personal information.

At AAPL, we value the trust you place in us. We recognize the importance of your personal data and are committed to handling it responsibly, securely, and transparently. We encourage you to carefully read this Privacy Policy to understand how your data is managed.

Who does this Privacy Policy apply to?

This Policy applies to all individuals ("User") who interact with AAPL, whether as existing customers, prospective customers, or visitors accessing our offices, digital platforms, mobile applications if any, or websites.

AAPL is a registered Non-Banking Financial Company (NBFC) engaged in providing loans and related financial services. By availing our services or accessing our digital platforms, you agree to the terms outlined in this Privacy Policy.

Scope of Coverage

For the purposes of this Privacy Policy:

  • The term "AAPL" refers to AAPL Agarwal Assignments Private Limited, including its digital platforms such as the website, mobile applications, and any other electronic interface.
  • The term "Services" refers to the financial products and services offered by AAPL, including but not limited to Loans, loan processing, repayment management, and related support functions.

This Privacy Policy describes the type of information we collect, how we use it, the purposes for which it may be processed, and the safeguards we maintain to protect your data. We may update this Policy from time to time to reflect regulatory changes, operational needs, or technological advancements.

Consent

By accessing our website, mobile application, or any other digital platform, and by availing the financial products or services offered by AAPL Agarwal Assignments Private Limited ("AAPL"), the User provides consent to the following:

  • Acceptance of the terms of this Privacy Policy, in addition to the terms of use of AAPL's website, mobile application, and product-related documents.
  • Collection, storage, and processing of data in connection with availing Loans or other financial services offered by AAPL.
  • Consent for collection and verification of data in relation to Aadhaar-based authentication (Aadhaar eKYC/OKYC) or verification through authorized facilities provided by UIDAI, CKYC Registry (CERSAI), DigiLocker, or any other government-approved entity, as permitted under applicable laws.
  • Use of contact information for communications relating to loan servicing, repayment reminders, product updates, and (subject to User preference) marketing or promotional activities.
  • Retention and storage of User data in accordance with AAPL's internal policies, as well as regulatory and statutory requirements.
  • Consent for electronic mandate (e-Mandate) registration using e-Signature or any other legally valid authentication method.

Types of Information

This Privacy Policy applies to all categories of information ("Information") that may be collected by AAPL Agarwal Assignments Private Limited ("AAPL") from its Users. Such information includes but is not limited to:

a. Personal and demographic data such as:

  • Name, age, date of birth, gender, address, mobile number, email ID, photograph, and government-issued identification numbers (e.g., Aadhaar, PAN, Passport, Voter ID).
  • KYC documents submitted by the User or accessed from authorized sources like CKYC Registry, UIDAI, DigiLocker, etc.
  • Financial details such as bank account information, salary slips, credit scores, provident fund details, GST information, or other data required for loan eligibility assessment and processing.

b. Technical and usage-related data which may or may not be personally identifiable, including but not limited to:

  • IP address, device details, browser type, operating system, cookies, geolocation, and usage patterns collected while accessing AAPL's website, mobile application, or other digital platforms.

For the purposes of this Privacy Policy, all such categories of data shall collectively be referred to as "Information".

Sources of Information

AAPL may collect Information from the following sources:

  • Directly from the User during the loan application process, whether online or offline.
  • Automatically from the User's devices, including browsers, mobile applications, or through the use of cookies, pixels, and similar technologies.
  • From authorized third parties, such as service providers, agents, verification agencies, CKYC Registry, UIDAI, DigiLocker, credit bureaus, or other government/regulatory databases.
  • From communications with the User, including emails, SMS, or other digital correspondence, subject to User's consent and in compliance with applicable laws.

Purpose of Collection and Use of Information

The information collected from Users may be used by AAPL Agarwal Assignments Private Limited ("AAPL") for the following purposes:

  • To provide Users with financial services related to AAPL's core business, including Loans, and any services incidental or ancillary thereto.
  • To promote and inform Users about AAPL's products and services.
  • To evaluate the performance of existing products/services and to design, improve, or develop new offerings.
  • To deliver services effectively, and to enhance, refine, or upgrade the User experience on AAPL's website.
  • To comply with applicable laws, regulations, and reporting requirements, including those relating to credit reporting and regulatory compliance.
  • To share, transfer, or process User information, to the extent permitted under applicable law or agreement, in connection with the financial services provided by AAPL, its group entities, partners, or authorized third parties.
  • To inform Users about exclusive offers, promotional campaigns, customized recommendations, and location-based financial services, wherever applicable.
  • To integrate and display relevant third-party content or offers when Users engage with advertisements through AAPL's website.

Cookies

Cookies are small data files stored on a User's computer or device when visiting a website. While cookies may contain unique identifiers, AAPL Agarwal Assignments Private Limited ("AAPL") ensures that sensitive personal information such as name, account number, or financial details will not be stored in cookies.

AAPL may use cookies for the following purpose:

  • To temporarily store the User's mobile number or related session data for authentication during a single session, which will be deleted upon log-off.
  • To use persistent cookies that record non-personal information (such as browser type, ISP, operating system, or clickstream data) and for basic profiling purposes (e.g., age group, gender, or income category).
  • To improve User experience by using cookie data to display relevant content, offers, or services.
  • To store User preferences to simplify navigation on AAPL's website and make future visits smoother.

Salient Features

  • AAPL is committed to protecting the privacy of its Users in compliance with applicable laws and regulations governing data protection and privacy.
  • Except where required for regulatory compliance, service provision, or authorized third-party support, AAPL will not share User information with any external organization. Any sharing will be limited to what is necessary for completing transactions, meeting legal obligations, or delivering services, as permitted under applicable laws.
  • AAPL may use collected information to enhance the User experience and, where appropriate and lawful, to inform Users of relevant offers, services, or financial products.

Data Governance And Training

At AAPL Agarwal Assignments Private Limited ("AAPL"), we are committed to maintaining complete transparency with our customers regarding how their information is governed, processed, and protected. Data governance is a key pillar of our privacy framework, enabling us to deliver secure and reliable services.

We adopt strict internal standards on data governance, focusing on:

  • Data Quality: ensuring the information we collect and maintain is accurate and up to date.
  • Data Minimization: collecting only such information that is necessary for lawful business or regulatory purposes.
  • Data Accuracy and Accessibility: keeping data correct and accessible only to authorized personnel on a need-to-know basis.

We recognize that customer privacy is a matter of utmost importance. Therefore:

  • Data is used strictly for lawful purposes, in line with customer consent and regulatory requirements.
  • Our employees are trained to handle all customer information ethically and responsibly, including following secure practices such as data classification and confidentiality protocols.
  • Data exposure to third parties is strictly minimized and is permitted only when necessary for service delivery, legal compliance, or as authorized by the customer.

Our governance framework emphasizes accountability, confidentiality, and continuous improvement. AAPL regularly reviews and updates its data handling policies to ensure compliance with applicable laws and to maintain the trust and confidence of its customers.

Security

Protecting the privacy and confidentiality of User Information is of paramount importance to Agarwal Assignments Private Limited ("AAPL"). We take appropriate technical, organizational, and administrative measures to safeguard personal and financial information entrusted to us.

Our security practices include:

  • Technical and Administrative Safeguards: We implement reasonable management, IT, and administrative measures designed to protect against unauthorized access, misuse, or loss of User Information.
  • Data Encryption & Access Controls: Sensitive data is protected through encryption and masking methodologies, and access is restricted strictly on a need-to-know basis to authorized personnel only.
  • Monitoring & Preventive Controls: AAPL deploys security tools and practices to detect, prevent, and mitigate unauthorized attempts to access User Information or disrupt services.
  • System Updates: We maintain an IT infrastructure with regular system updates, patches, and monitoring to reduce vulnerabilities.
  • Third-Party Safeguards: Where services are outsourced to third parties (such as IT support, payment processors, or verification agencies), AAPL ensures that such parties follow adequate security and confidentiality standards in line with contractual obligations and applicable laws.

Any unauthorized usage, unlawful sharing, or breach of confidentiality of User Information is treated as a serious violation and may invite legal action in accordance with applicable law and contractual provisions.

Our responsibility is to keep Users informed of our approach to data security and to continuously enhance our measures in line with industry standards and evolving risks.

Data Retention

AAPL may retain the following categories of information for the periods mentioned below, in compliance with applicable laws and regulatory requirement:

S.No Kinds of Information Retention Period
1 Loan Files, including application Form, Income documents, agreements and related records collected at the time of loan application and during the relationship. For the duration of the relationship and 5 years from closure of loan account.
2 KYC Documents (including proof of Identify, proof of address openings forms, and related records). For the duration of the relationship and at least 5 years after cessation of the relationship.
3 Customer walk-in Complaint/Suggestion register and grievance redressal records. 5 Years
4 Records of all transactions between AAPL and the User. 5 Years from the date of transaction
5 Records relating to deceased constituents (including death certificates, affidavits, disclaimers, succession certificates, and related correspondence). 8 Years
6 Statutory and regulatory reporting documents submitted to regulatory authorities (e.g., RBI, FIU-IND). As per the period prescribed under applicable law (generally 8 years, unless otherwise specified).
7 Audit logs, IT system records, and access logs relevant to loan processing and servicing. Minimum 8 years or as required under law.

Information may be retained for a longer period in the following circumstance:

  • Where required for any ongoing or potential investigation, inquiry, or proceedings before courts, tribunals, forums, or commissions.
  • When mandate by the regulatory authorities, law enforcement agencies, or applicable laws.
  • For internal audit, risk management, fraud monitoring, and compliance purposes.
  • To improve or enhance AAPL's products and services, subject to anonymization or de-identification of personal information wherever possible.

Service Providers

AAPL may engage third-party service providers, partners, and individuals to support its operations and deliver services. Such third parties may access and process User Information strictly on a need-to-know basis and only for the purposes for which the data was originally collected.

The purposes may include (but are not limited to):

  • Facilitating AAPL's products or services.
  • Providing services on behalf of AAPL.
  • Performing ancillary services such as IT support, customer verification, payment processing, or analytics.
  • Assisting AAPL in analysing how its services are used and improving service delivery.
  • Supporting compliance, regulatory, or reporting requirements.

All third-party service providers engaged by AAPL are contractually obligated to maintain confidentiality and are restricted from using the information for any purpose other than providing services to AAPL.

Responsibility of User

Users acknowledge and agree to the following responsibilities while accessing and using the services of AAPL:

  • No direct disclosure requests: AAPL and/or its employees will not contact Users directly for disclosure of personal information except where required for the purposes mentioned in this Privacy Policy. Users are solely responsible for verifying the identity of anyone requesting personal information before disclosure, preferably by contacting AAPL through its official website or customer support.
  • User's negligence: AAPL shall not be held liable for any privacy breach arising due to User's negligence.
  • Official channels only: Users should access AAPL's products and services only through official websites or authorized links of AAPL.
  • Risk awareness: Users acknowledge the potential risk of data/privacy breaches and shall be solely liable for any unauthorized disclosure or misuse of their personal information arising from their conduct. Users are expected to exercise utmost caution to ensure that sensitive data (such as passwords, financial details, and account information) is not shared or made accessible through any unauthorized means.

Safety Measures for Users

To minimize risks, Users are advised to:

  • Always check for "https" in the website's address bar before entering any personal information.
  • Avoid using third-party extensions, plug-ins, or add-ons that may compromise data security.
  • Manually type login or personal details rather than relying on browser/mobile auto-fill functions.
  • Avoid accessing suspicious, unauthorized, or malicious websites or platforms.
  • Disable cookies before visiting untrusted websites to prevent tracking by third parties.
  • Refrain from responding to emails or messages from unknown/unverified sources.
  • Review the Privacy Policy of any platform before proceeding with a transaction involving personal data.
  • Install only genuine software, applications, and updates from reliable sources.
  • Avoid clicking on unidentified weblinks or electronic links shared via email, SMS, social media, or other channels.

Website & Links to Other Sites

AAPL's official website may include links to external or third-party websites. If you choose to access such links, you may be directed to sites that are not operated or controlled by AAPL. Please note that AAPL does not have any control over the content, privacy practices, or policies of such third-party websites and shall not be responsible for any information or material provided therein. We strongly encourage Users to review the privacy policies and terms of any external sites before providing personal or financial information.

Amendment of Privacy Policy

AAPL reserves the right to amend, modify, or update this Privacy Policy at any time in accordance with applicable laws and regulatory requirements. Any such changes will be effective immediately upon being posted on this page. Users are advised to review this Privacy Policy periodically to stay informed about how their information is being protected and used.

Disclaimer

  • Agarwal Assignments Private Limited ("AAPL") is a registered Non-Banking Financial Company (NBFC) engaged in providing financial services, including short-term credit facilities such as Loans. The terms and conditions set out in the respective product/service documentation shall prevail in the event of any inconsistency with this Privacy Policy or related information.
  • Any additional information such as facts, statistics, illustrations, or general content provided on this website is sourced from publicly available information and is intended only for reference purposes. While AAPL strives to ensure accuracy, it does not guarantee that such information is free from errors, omissions, or delays. Users are encouraged to exercise independent judgment and seek expert advice, where necessary, before relying on such information. The final responsibility for decisions taken rests solely with the User.

Contact Us

If you have any queries, concerns, or wish to exercise your rights under this Privacy Policy, you may contact us through the contact details provided on our official website.

[Insert AAPL's contact email/phone/website link here]

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