Effective Date: 1 Sept 2022
We may collect personal identification and communication information which includes but is not limited to your personal details (like name, home/office address, date of birth, father’s name, mother’s name, your photograph etc.), contact details (like home/work phone number, official email address, personal email address, personal mobile number etc.), Business/work related information like (employee ID number, tax identification number, social security number etc.), personal identification proof like (UID, Driving License, passport, PAN number), Credit and financial information like (banking accounts related financial information, Bureau reports, Loan documents, purchase histories etc.) as may be necessary and applicable subject to the nature of the transaction and where permitted for diversity and monitoring purposes, we may collect information concerning your gender. Additionally, device location and information, messages, contacts, call logs, emails, log information like your search queries, IP address, crashes, date and time, browser web storage, application data caches, Cookies and similar technologies and data of the such Customers (collectively and individually referred to as “Customer Data”).
Personal Identification and communication information and application related information are hereinafter collectively referred to as “Customer Data”.
RAINPAY INDIA PRIVATE LIMITED, a company incorporated and registered under the Companies Act, 2013 with corporate identity number U74140KA2020FTC142026and having its registered office at c/o 91 Springboard, Pavilion 175 AND 176, Dollars Colony, JP Nagar, Bannerghatta Main Rd, Bengaluru – 560076.
The Company Rainpay India Pvt. Ltd, presently owns and operates a payroll based online lending platform (“Platform”) which facilitates short-term lending to and recovery of loans from individuals and other persons (“Borrowers”) and provides specified services relating to financial intermediation for various banks, regulated financial institutions/entities, non-banking finance companies and other lenders (“Lenders”).
Rain is committed to protect the personal and financial information submitted by its customers (“you”) and would endeavour to protect such information from unauthorized use.
Our Privacy Practices
Information We Collect
When you connect one or more of your accounts with other financial institutions to the Rain App or to your Rain Account, we also may collect information to identify you, or to help verify that you are the true owner of the account(s), before connecting your account(s).
2. Information received from your devices and device location.
We collect and monitor the information about the location of your device to provide serviceability of your loan application and facilitate the Lender to reduce risk associated with your loan application and to provide pre-approved customised loan offers. This also helps us and the Lender 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.
Based on explicit consent given by you, as part of the Loan Application process, we will collect the following information from the Device:
We don’t collect, read or store your personal SMS from your inbox. We collect and monitor only financial SMS sent by 6-digit alphanumeric senders from your inbox which helps us in identifying the various bank accounts that you may be holding, cash flow patterns, description and amount of the transactions undertaken by you as a user to help us perform on behalf of the Lender,a credit risk assessment which enables us to determine your risk profile and to provide you with the appropriate credit analysis. This process will enable you to take financial facilities from the regulated financial entities available on the Platform. This Financial SMS data also includes your historical data.
We collect a list of the installed applications’ metadata information which includes the application name, package name, installed time, updated time, version name and version code of each installed application on your device to assess your credit worthiness and enrich your profile with pre-approved customized loan offers from the regulated financial entities available on the Platform.
We require the camera information permission to provide you an easy/smooth experience and to enable you to click photos of your KYC documents along with other requisite documents and upload the same on the App during your loan application journey.
We require storage permission so that your KYC and other relevant documents can be securely downloaded and saved on your phone. You can then easily upload the correct KYC related documents for faster loan application details filling and disbursal process. This ensures that you are provided with a seamless experience while using the application.
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. 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.
The App 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. We ensure that our third-party service provider takes extensive security measures in order to protect your personal 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.
3. Information collected from your financial institutions.
Whether Rain collects or maintains your information collected from the financial institutions you use, such as your bank, may depend on how you use the Rain App or Rain’s Services. Generally speaking, when you link your primary bank account to the Rain App or to Rain’s Services, we may collect several categories of your information, including:
4. Information we receive about you from other sources.
We also collect your information directly from other persons, including credit information companies and our service providers. For example, Rain may collect and maintain your information from service providers that help Rain to identify you and to verify that you are the individual who is authorized to use Rain’s Services.
Why We collect, Use and Store the Customer Data
1. Collection of Customer Data for propagating business
From time to time, we may request aforementioned Customer Data from you to process your applications through our Rain App, and to get valuable feedback from your experience on our Rain App. In addition, we may also use your Customer Data for other business purposes or in order to help serve you better, such as informing you of new services, or alliances that could help you in your career or business. Your posting of any such Customer Data is strictly up to you. While you can visit the Rain App without disclosing any Customer Data, however, to apply or to register on the Rain App there are web pages that require such information to complete certain functions, thus these web pages may not be available to you, if you decide not to reveal the information requested. We will take reasonable steps to ensure that your Customer Data is accurate and complete.
2. Disclosure to third parties
Apart from the Lender, we may disclose Customer Data to third parties. This disclosure may be required for us to check your eligibility for, provide you access to, and enable fulfilment of any services being provided to you, or to comply with any legal obligations, to enforce user agreements, to facilitate any marketing and advertising activities, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to any services being provided to you. You expressly consent and agree to such disclosures to third parties.
3. Collecting Customer Data for online surveys
At times, we conduct online surveys to better understand the needs and profile of our visitors. When we conduct a survey, we will inform you about how we will use the Customer Data prior to your taking the survey. If you do not want to participate in the survey, you may refrain from contributing to it at your own discretion.
4. Collecting domain information
The Rain App may use a technology known as web beacons – sometimes called single-pixel gifs – that allow this Rain App to collect web log information. A web beacon is a graphic on a web page or in an email message designed to track pages viewed or messages opened. Web log information is gathered when you visit the Rain App by the computer that hosts the Rain App (called a “webserver”). The webserver automatically recognizes some information, such as the date and time you visited the Rain App, the pages you visited, the website you came from (to the extent you have given your consent), the type of browser you are using (e.g., Internet Explorer), the type of operating system you are using (e.g., Windows 10), and the domain name and address of your Internet service provider. If you have given your consent, we may also include web beacons in promotional email messages in order to determine whether messages have been opened.
To the extent you have given your consent, the Rain App uses a technology called a “cookie”. A cookie is a piece of information that our webserver sends to your computer (actually to your browser file) when you access a website. Then when you come back, the Rain App will detect whether you have one of our cookies on your computer. Our cookies help provide additional functionality to the Rain App and help us analyse Rain App usage more accurately. For instance, our Rain App may set a cookie on your browser that keeps you from needing to remember and then enter a password more than once during a visit to the Rain App.
6. IP address
The Rain App uses Internet Protocol (IP) Addresses. An IP Address is a number assigned to your computer by your Internet service provider so you can access the Internet. Generally, an IP address changes each time you connect to the Internet (it is a “dynamic” address). We use your IP address to report aggregate information on use and to help improve the Rain App.
You should be aware that this Rain App is not intended for, or designed to attract, individuals under the age of 18. We do not collect personally identifiable information from any person we actually know is an individual under the age of 18.
Areas of this Rain App that collect your Customer Data use industry standard secure socket layer encryption (SSL); however, to take advantage of this your browser must support encryption protection (found in Google Chrome, Internet Explorer release 3.0 and above).
Use and disclosure of Customer data
We protect Customer Data against unauthorized use in the same manner in which we protect our confidential information. However, in following conditions, we may share Customer Data:
However these parties would be required to use the information obtained from Rain either for the purposes mutually agreed with Rain or for the purposes expressly permitted by the applicable laws exclusively. Rain will endeavour to take all reasonable steps to ensure that the confidentiality of the Customer Data is maintained by imposing strict confidentiality standards on all the private and non-statutory third parties to whom it discloses such information. Further, Rain shall not retain the information for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force.
In addition to the above, we use the information we collect to operate, improve, and protect the Services we provide, and to develop new services. For example, we use your information:
Rain is strongly committed to protecting the privacy of its customers and has taken all necessary and reasonable measures that commensurate with the information assets being protected to ensure confidentiality of the Customer Data and its transmission through the world wide web and it shall not be held liable for disclosure of the confidential information when in accordance with this policy or in terms of the agreements, if any, with the Customers.
In addition, we use small bits of data called “cookies” stored on user’s devices to stimulate a continuous connection. “Cookies” let us store information about your preferences and passwords and allow you to move to different pages of our Website/ App without having to re-enter your password information. Any information collected is stored in secure databases protected via a variety of access controls and is treated as confidential information by us. Therefore, you should be careful with usage of the username and password by maintaining confidentiality and ensure that you do not knowingly or accidentally share, provide and facilitate unauthorized use of it.
Where We store the Customer Data
The Customer Data you provide to us via the Rain App is transferred to and stored on our in-house secure database and is processed to support your enquiry to become a User on the Rain App. The Rain App and database are both hosted within India. The Customer Data, however, may be maintained or processed by our staff or our affiliates operating outside India.
We collect the data to ensure a proper connection build-up and system security, and to improve the Rain App. The legal basis for such processing is applicable data protections laws including the IT Act. We have a legitimate interest in the provision of a safe access to the Rain App and Services, in technical security, rectification of malfunctions as well as detection and tracking of any unauthorized access or attempt of access to the Rain App.
Our Steps to Protect your Information
We take steps designed to protect your information that we collect, maintain, or disclose. These steps include maintaining information security controls, such as encryption technologies when transferring data or even when storing data, firewalls, and controls over the physical access to our systems. We regularly evaluate the security controls that we use, as well as the controls that our service providers use, for protecting the security and confidentiality of your information. Our goal is to maintain effective security controls, as measured by relevant industry standards or by independent security auditors, for all of the ways that you can use Rain’s Services.
Rain may keep your information for as long as necessary to fulfil the purposes for the information is collected. In addition, for some types of your information, Rain may apply a longer retention period, such as for research or statistical analyses, except when storing or using that information for longer periods of time is not permitted under applicable law. As permitted under applicable law, even after you stop using the Rain App or terminate your account with Rain, we may retain your information.
Our Rights to Disclose your Information
Rain makes various types of disclosures of your information to other persons as permitted by law. Our disclosures of your information may apply to some or all of the categories of your information that we collect. For example, Rain may disclose all of the types of your information with the Lender, with your employer or with your financial institution, consistent with your consent or instruction. Rain also discloses, or reserves the right to disclose, your information:
We may collect, use, process, or disclose your information in an aggregated or anonymized manner (i.e., in a manner that does not identify you personally) for any purpose permitted under applicable law.
As a convenience to our visitors, this Rain App may contain links to a number of sites that we believe may offer useful information. The policies and procedures we described here may not apply to those sites. We suggest contacting those sites directly for information on their privacy, security, data collection, and distribution policies.
We will process, disclose or share your Customer Data only if required to do so by law or in good faith belief that such action is necessary to comply with our contractual obligations, legal requirements or legal process served on us or the Rain App.
How long we retain your Customer Data
We will retain your Customer Data only for as long as we need, we need it for our legitimate interest in accordance with applicable law, to fulfil your registration and application process and to perform services as you have opted for, or to meet legal requirements, after which we will take steps to delete your Customer Data or hold it in a form that no longer identifies you.
Verification of Data
To the extent permitted by law, it will be necessary for us to verify the details you have supplied. Such verification could be done through third party service providers, who shall be bound by the obligation of confidentiality and data protection.
Where permitted by applicable law, we reserve the right to monitor, intercept, access and erase all information, material, data and communication (including emails, telephones conversations, and voicemail recording), regarding registration and further processing of your application through the Rain App.
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