Privacy Policy

Introduction

The contents of this Privacy Policy along with the Terms and Conditions (“Terms and Conditions”) available at https://www.apollofinvest.com (the “Website”) are applicable to all hyperlinks under the Website and the Apollo’s  Mobile Application Software (the “App”). Any access of AFIL’s Services (defined below) through the Website or through the App or on any other Website of AFIL or other partner banks and financial institutions (“Co-Lending Partner”) or other third party sites (“Service Sites”) will be governed by this policy which sets out the basis on which any personal data is collected from you or the data that you provide to AFIL and is processed by AFIL. You hereby acknowledge having read and accepted the same by use or access of the App.

This Privacy Policy states the following:

i. The type of information collected from the users, including personal information relating to an individual;

ii. The purpose, means and modes of collection, usage, processing, retention and destruction of such information; and

iii. How and to whom AFIL will disclose such information.

AFIL respects your privacy and recognizes the need to protect the personal data or information which you share with AFIL. AFIL assures to follow appropriate and necessary standards when it comes to protecting your privacy on the App.

The Company, in adherence to CICRA laws (collectively CICRA Act, CICRA Regulations, CICRA Rules) and para 66 of RBI SBR Master Directions, has taken necessary steps to securely handle and safeguard borrower’s credit information ensuring the protection of customer privacy. Further, privacy principles have been adopted that govern data collection, processing, and retention for all forms of credit information, whether obtained directly from customers or through credit reports. In accordance with the regulatory requirements, the Company collects, processes, and reports credit information, including historical data, as per the specified format. Data collection is done with the borrower’s consent and may involve obtaining credit reports from any one or more Credit Information Companies (CICs). This information is utilized for various lawful purposes such as verifying borrower’s identity, assessing creditworthiness, and maintaining accurate records. To ensure the security of the information, necessary technical, operational, and procedural safeguards and protocols have been put in place, as per the Information Security Policy and KYC Policy. Security measures include storing data on secured servers, employing encryption norms, and restricting access to authorized personnel, thereby preventing unauthorized access, misuse, or disclosure of personal information. The Company maintains the accuracy and completeness of records and reports the data as per the frequency defined under the extant regulations, to the CIC. The Company further ensures timely response to borrower requests for modifications and aligns its practices with applicable RBI regulations for compensating customers for delayed updation or rectification of credit information. The grievance redressal mechanism of the Company for the purpose also includes recourse through the RBI Ombudsman for wrongful denial of compensation.

Consent

AFIL will only be using the information for providing Services to you. By affirming your assent to this Privacy Policy, you provide your consent to such collection, use, storage, processing and disclosure as set out in this Privacy Policy and the Terms and Conditions. The information received by AFIL will not be shared with any third party or third party service providers for the purposes of advertising or marketing. AFIL will only be using the information for providing Services to you.

What Information We Collect

AFIL will track the internet protocol address from which users/individuals access the App and analyze this data for trends and statistics. Along with receiving information from third parties about you, AFIL may also collect your information in the App by information filled in forms or by your correspondences with AFIL, by way of e-mail or chat, registering to use the App, downloading or registering the App, subscribing to any of AFIL’s financial services or products (“Services”), searching for an App, sharing data via the App’s social media functions, entering a competition, promotion or survey and reporting a problem with the App or a Service Site through your computer, mobile phone or any other device which may include, but is not limited to, your internet protocol address, device information including but not limited to identifier, name and type, operating system, approximate location, mobile network information, device phone number, SIM card details, age, username, password and other registration information, financial and credit information including your mobile account details, bank account details, and bank verification number (where applicable), personal description , photograph, time zone setting, information stored on your device including SMS logs, Calendar data, presence of fixed number of apps installed and standard web log information including but not limited to your browser type, traffic to and from AFIL’s App, the pages you accessed on AFIL’s App, the pages you visited before opening the App, and the webpages you access after you leave the App traffic data, location data, weblogs and other communication data and any other available information. When you use the Services, AFIL may also store information based on your usage history, this includes, but is not limited to, details of your subscription, content you viewed, event information, clickstream information, and cookies that may uniquely identify your browser or your account. AFIL may also store the unique application number provided to you while you install or uninstall a service or when a service searches for automatic updates. AFIL may also collect information about you from any contact you have with any of AFIL’s Services or employees, such as, with AFIL’s customer support team, in surveys, or through interactions with AFIL’s affiliates.

Why We Collect Information

The Information we collect from you or from Third Party Partners are used and processed for (a) Contractual Purposes (b) Legal Obligations (c) Legitimate Interests.

1. Contractual Purposes

a. providing any of the Services to you including and not limited to determining whether or not to provide a service to you, the applicable terms of such service and the terms and conditions applicable to such service. We are unable to make this determination unless we collect and process data in accordance with our terms and conditions; or

b. communicating with you regarding requests about our Services or Services provided to you.

2. Legal Obligations:

a. identification, validation, and verification of your identity;

b. processing of payment and settlement instructions;

c. managing investment of funds on your behalf;

d. collection of loans and any amount outstanding from you;

e. compliance with any risk, regulatory duty or lawful obligation including responding to regulators or supervisors, carrying out anti money laundering investigations, record keeping obligations, etc;

f. carrying out risk analysis and assessments of our Services, Service Sites, and market;

g. compliance with codes of conduct or best practices; or

h. troubleshooting issues with our Services and Service Sites;

3. Legitimate Interest

a. fraud detection and prevention of other illegal use of our Services and Service Sites;

b. improving our Services to you and your experience with us;

c. offering rewards and other incentives to our customers;

d. collaborating with Third Parties to provide a Service or to improve our services to you;

e. educate you about Services or any other information that might be useful to you as our customer;

f. improving our business, processes, policies, etc;

g. improve our data quality;

h. carry out research, experiments, and tests; or

i. marketing, advertising, and sensitization of our Services;

When you use our services on the mobile App, we also collect the following information from your smartphone;

● Location: This app collects location details for each loan,one time to verify your location, and current address, to ensure serviceability, and to identify unusual activity to prevent against any fraud. We do not collect location when app is in background.

● Device: This app collects and monitors specific information about your device including your hardware model, operating system and version, user profile information to uniquely identify the devices and ensure that unauthorized devices are not able to act on your behalf to prevent frauds. We do not collect any unique device identifiers like IMEI or serial number.

● SMS:  This app periodically collects and stores SMS data like sender names, SMS body, received time and transmits the data to third parties. This data is used to understand your income and spending patterns which help us in credit evaluation and help us in facilitating higher limits, faster approval rates. Your personal or private messages are not read nor collected.

● Installed apps: This app periodically collects information about the apps installed on your device to provide better personalized services and improve our credit risk assessment.

● Camera: Our system ask for one time access to camera for customer onboarding/said KYC process.

We access this information through your mobile device operating system when you give consent to your device’s permissions on our App.

AFIL develops statistics that are helpful to understand how AFIL’s Visitors can use the App. AFIL uses this information in the aggregate to measure the use of the App and to administer and improve the same. This statistical data is interpreted by AFIL in its continuing effort to present in the App, content that Visitors are seeking in a format they find most helpful.

The information AFIL collects and analyzes is completely anonymous and is used to improve the Services and your loan offering. You agree that AFIL or AFIL’s third party service providers can collect your IP address or other unique identifier. At times, AFIL also uses these identifiers to collect information regarding the frequency with which the Visitors visit various parts of the App. AFIL, may combine your internet protocol address with other personal information for AFIL’s own marketing and for market research purposes, including internal demographic studies, to optimize AFIL’s products and Services and customize the App for you.

AFIL may combine your visitor session information or other information collected through cookies, web beacons and other technical methods with any personal information in order to understand and improve your App experience and to determine what products, promotions and Services you prefer or are likely to be of interest to you.

Cookies, web beacons and other technical methods may involve the transmission of information either directly to AFIL or to another party authorised by AFIL to collect information on AFIL’s behalf. The information from use of these technical methods may be collected in a form that identifies you personally.

There are times when AFIL may collect personal information from you such as name, physical and email address, citizenship and phone number. If you choose not to provide the information we request, you can still visit the App, but you may be unable to access certain options, offers and Services.

In case you wish to prevent any such usage by AFIL, you are required to inform AFIL within 10 (ten) days of being informed of the proposed use that you do not wish to disclose such information. You can exercise this right at any time by contacting grievanceredressal@apollofinvest.com.

Where We Store Your Personal Data

Wherever AFIL has provided or you have chosen a PIN to access any part of the App or Service Sites, you shall be responsible for keeping the PIN confidential.AFIL stores your personal information only at servers located in India

 Also, the data AFIL collects from you and transfers or stores may be at a location/destination within the country of your origin or residence. The data collected from you may be processed by the staff of AFIL or any supplier or AFIL or a third party operating outside the country of your origin or residence.

Retention of Information:

AFIL stores your personal information only at servers located in India. We shall only retain basic personal information such as your name, your address, your contact information which are required to be stored for carrying out our non-lending services. For other personal information collected as part of our outsourcing services being provided to our Partners, we shall collect such information upon the instructions of the Partners and thereafter transfer the same to the Partners upon the completion of the preliminary onboarding.

Retention of information is done as per this policy and in compliance with applicable law/regulatory requirements in India and as mandated in our arrangements with our business partners to provide services to you, unless such consent is withdrawn by you.

We retain your Information as long as the purpose of its usage exist, after which the same is archived or purged or deleted by us except in case where the retention is required as per Applicable Laws. Further, we inform you that we retain Information even after you withdraw your consent partially or wholly, for longer period of time, when necessary or required to be retained by Us, under various Applicable Laws.

All non-personally identifiable information (non-PII) including SMS will be stored and used for a period of one (1) year. All other data such as name, address, contact details, etc. permitted in pursuant to regulatory guidelines, including DLG and such other data collected for the purpose of onboarding and operational servicing, will be retained for a minimum period of five (5) years.

In general terms, this will mean that your Information will be kept for the duration of our relationship with you and:

1. the period required by under Applicable Laws; and
2. as long as it is necessary for you to be able to bring a claim against us and for us to be able to defend ourselves against any legal claims. This will generally be the length of the relationship plus the length of any applicable statutory limitation period under Applicable Laws.

Google API Disclosure

AFIL's use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Cookies

AFIL’s App may store and use "cookies" so that AFIL can serve you better with customized information when you return to the App. Cookies are identifiers that are stored on your equipment’s browser directory. They are created when you download or visit our App. They keep track of your movements within the App, help you resume where you left off, remember your registered login and other functions.

Sharing of Information

AFIL may use the personal information that you have shared during the process of registration or otherwise for verification purposes, including your KYC data/documents. You agree and allow AFIL to share such information with our partner lenders for credit underwriting, third parties for verification purposes, credit information companies for reporting and with government agencies, including but not limited to the Reserve Bank of India (“RBI”) for the cause of an inspection or any other legal diligences which may be conducted by it. AFIL may also use the information you provide to update AFIL‘s consumer credit database.

When you visit the App, you agree that AFIL or any of AFIL’s partners/affiliates/collection agents may contact you from time to time to provide the offers/information of such products/Services that AFIL believes may benefit you or to get information about any repayments due or any other promotional or transactional information AFIL wishes to receive from you. You agree that AFIL may provide information collected from you to government authorities or credit bureaus as per the rules laid down by RBI or any court of law as per the applicable laws of India.

AFIL or any of AFIL’s partners/affiliate/ collection agents may contact you for any promotional, transactional or any other purpose by way of phone, SMS, email, push notification, Calendar notification, etc. However, AFIL may does not share the information provided to AFIL by you in any manner to any third parties for the purpose of advertising or marketing campaigns.

It is possible that AFIL may need to disclose personal information when required by law, such as responses to civil or criminal subpoenas, or other requests by law enforcement personnel. AFIL will disclose such information wherein AFIL has a good faith/ belief that it is necessary to comply with a court order, ongoing judicial proceeding, subpoena, or other legal process, or to exercise AFIL’s legal rights or defend against legal claims.

Disclosure to Third Parties

AFIL may disclose your personal information to third parties in the following events:

i. If AFIL sells or buys any business or assets, in which case AFIL may disclose your personal data to the prospective seller or buyer of such business or assets;

ii. If AFIL or substantially all of AFIL’s assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;

iii. If AFIL is under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request; and/or

iv. In order to report loan activity to any credit bureau; or for the purpose of publishing statistics relating to the use of the App, in which case all information will be aggregated and made anonymous.

Link to Third Party Websites

AFIL may link to third-party websites which may be AFIL’s integration partners. These third-party websites may collect information about you on those websites, and AFIL‘s Privacy Policy does not extend to such third party websites. Please refer directly to the websites of such third parties and their privacy policies.

Details of the third parties we share your personal information with are set out below:

Your Rights regarding the Data

Right to Access

You may request to access your data provided by you (or) processed by us. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Right to rectification

In the event that any personal data provided by you is inaccurate, incomplete or outdated then you shall have the right to provide us with the accurate, complete and up to date data and have us rectify such data at our end immediately. We urge you to ensure that you always provide us with accurate and correct information/data to ensure your use of our Services is uninterrupted.

Right to withdraw consent

To prevent further sharing of your data, you can also uninstall the App. Your device may have controls that determine what information we collect. For example, you can modify permissions on your Android device for access to Camera or Audio permissions.

Marketing Opt-Out

We may email or send push notifications to you from time to time about our latest offerings and updates. You may opt out of receiving such promotional emails from us by writing to us. You may also opt out of receiving emails and other messages from us by following the unsubscribe instructions in those messages. However, even if you have opted out of receiving information from us, we will still send non- promotional communications, such as repayment reminders and loan approvals message etc.
You can opt out of receiving push notifications through your device settings. Please note that opting out of receiving push notifications may impact your use of the App.

Others

You are provided with an option 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 (as defined under the RBI circular dated September 02, 2022 on “Guidelines on Digital Lending”). In case of withdrawal or modification of your consent or your amendment of any of your choices in this regard, we reserve the option not to provide the services or modify the services provided to you for which such information was sought.
Our platform is not intended for use by children and minors. Parents are requested to ensure that personal information is not provided by minors.

Revocation of consent and deletion of data :

Consent are required before we may collect, use or disclose your personal information, except in situations permitted by the law, such as during a fraud investigation, or where we are required to disclose information by court order.

You may also provide us with your implied consent for the collection, use, and disclosure of personal information necessary for the Identified Purposes. While we may rely on implied consent in certain circumstances, we will not collect, use or disclose your medical and health information, your employment and income information, or your banking, credit or financial information, without your express written or verbal consent.

You may withdraw your consent, subject to legal or contractual obligations and on reasonable notice, but this may limit our ability to provide you with the requested product or service. In the event that you wish to withdraw your consent, you should contact on grievanceredressal@apollofinvest.com for information regarding the implications of such withdrawal, and then if you choose to proceed, give the requisite notice.

Where permitted by law, you may be given the option to give your express consent to us to access your credit information from a credit reporting agency, and other agencies such as NSDL, CKYC records, Digilocker, etc. We will use this credit information for the purpose of assessing risk, providing you with a quote, and determining your eligibility for a premium discount. We may continue to retrieve your current credit score from time to time, while you remain a customer of ours, unless you withdraw your consent for us to do this.

Security Measures and Procedures

AFIL will not sell, trade or disclose to third parties any information derived from the registration for, or use of, any online Service (including names and addresses) without the consent of the user or customer save and except to any of AFIL’s affiliates for helping you in receiving loans or other Services in relation to the businesses of AFIL’s affiliates and as may be required by legal process or in the case of imminent physical harm to any persons. Further, AFIL will allow its affiliates to access the information for purposes of confirming your registration and providing you with benefits you are entitled to.

AFIL will take appropriate steps to protect the information you share with AFIL. AFIL has implemented technology and security features and strict policy guidelines to safeguard the privacy of your personal information from unauthorized access and improper use or disclosure. AFIL will continue to enhance AFIL’s security procedures as new technology becomes available.

AFIL may transmit the information collected from you through the internet to another country, among AFIL’s affiliates, for purposes such as for storage, or for carrying out the processing detailed above, or because of where AFIL’s servers are located.

Should you wish to delete your personal data that AFIL acquired from the Facebook platform, you may do so by contacting us at grievanceredressal@apollofinvest.com.

Changes to Privacy Policy

AFIL may change this Privacy Policy from time to time without requiring any consent from anyone. If AFIL’s Privacy Policy changes in the future, it will be posted here and a new effective date will be shown. You should access AFIL’s Privacy Policy regularly to ensure you understand AFIL’s current policies. If you have questions about the Privacy Policy, please email AFIL at grievanceredressal@apollofinvest.com and reference the Privacy Policy in your subject line. AFIL will attempt to respond to all reasonable concerns or inquiries on a best efforts basis within a reasonable period of time.

Governing Law and Dispute Resolution

This Privacy Policy shall be governed in accordance with the laws of India and any disputes arising out of or in connection with this Privacy Policy shall be subject to exclusive jurisdiction of the courts in Mumbai.

Complaints and Grievance Redressal

If you contact us to provide feedback, register a complaint, or ask a question, we will record any Personal Information and other content that you provide in your communication so that we can effectively respond to your communication. Any complaints or concerns in relation to your Personal Information or content of this Website or any dispute or breach of confidentiality or any proprietary rights of User during use of the Website or any intellectual property of any User should be immediately informed to the co-ordinates mentioned below in writing or by way of raising a grievance ticket through the hyperlink mentioned below:

Apollo Finvest (India) Limited

Pooja Gohel- Grievance Redressal Officer
Address: 301, Plot No. B-27, Commerce Centre, Off New Link Road Near Morya House, Andheri West, Andheri, Mumbai, Mumbai, Maharashtra, India, 400053
Ph: 7700986861
Grievances portal: grievanceredressal@apollofinvest.com

Omnibus Clause:
All extant & future master circular/directions/guidance/guidance notes issued by Regulatory Authorities and other applicable regulations from time to time would be the directing force for the Privacy Policy and will super cede the contents of this policy.