We, at FINAGLE FINANCE PRIVATE LIMITED RBI Approved NBFC, ND-NSI-NBFC (“FINAGLE” or “We”) understand Privacy and its value. Therefore, it is all the more important for us to make You (“You” or “Customer” or “User”), its website (“Application” or “App”) (collectively, the “Platform”) understand the reason behind collection of your information and its usage and the manner in which we collect, use, store and share information about you (“Privacy Policy”).
This Privacy Policy has been prepared in compliance with:
A. Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.
B. Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021
C. Digital Lending Direction 2025 issued by the Reserve Bank of India (RBI), D. Other applicable acts, regulations and rules which requires the publishing of a privacy policy for handling of or dealing in personal information including sensitive personal data or information and all applicable laws, regulations, guidelines provided by applicable regulatory authorities including but not limited to the RBI.
1. CONSENT
1.1 You hereby provide your explicit, informed, and freely given consent for the collection, processing, storage, sharing, and usage of your data by FINAGLE FINANCE PRIVATE LIMITED (“FINAGLE”), solely for the purposes described in this Privacy Policy, and in compliance with applicable Indian laws and regulations.
1.2 Your consent is obtained through clear and auditable means, including, but not limited to, SMS-based consent, OTP-based confirmation, electronic forms, and in-app notifications, depending on the nature of the data being collected. We will never collect or use any personal data, financial data, or device-level data without your specific consent for that category of data.
1.3 SMS Consent is obtained from you solely for the limited purpose of assessing your creditworthiness and processing your loan application. The consent obtained through SMS access is restricted to financial data only and does not extend to any personal or non-financial information. We do not access, read, or store any personal messages, one-time passwords (OTPs), private conversations, or promotional content. We may access SMS log of customers’ mobile phone and reads only the non-personal SMS sent by 6-digit alphanumeric senders to identify and collect only those SMS that depict any nature of financial transaction from various bank accounts that customer may be holding, for analysis of cash flow patterns, description and amount of the transactions undertaken as a user to help us verifying/ estimating the income/ expenses pattern, cash flow analysis and perform a credit risk assessment on him/ her and provide him/ her with the appropriate credit analysis or a loan offer.
1.4 Your consent specifically includes:
A. Collection of information required for credit assessment and underwriting of loan products and value-added services offered by FINAGLE or its Lending Service Providers (LSPs) / Digital Lending Apps (DLAs) third parties, service providers, etc based on your requirement to avail such Services
B. Access to your mobile device’s location, camera, and microphone only for e-KYC or video KYC verification purposes.
C. Access to your credit bureau data, bank statement, GST returns, and related information only after receiving your express and recorded consent for each such instance.
D. Secure sharing of your personal data with regulated entities and service providers for the sole purpose of delivering the services you have requested or availed.
1.5 You may withdraw your consent at any time by contacting our Grievance Officer or through the Platform settings. However, please note that withdrawal of consent shall not affect the legality of data processing done prior to such withdrawal. Further, consent withdrawal may affect your ability to access or use certain services, especially those already availed and/or required to comply with regulatory obligations. We ensure that the identity of the Regulated Entity (RE), Lending Service Provider (LSP), and Digital Lending App (DLA) involved in the transaction is disclosed to the borrower at every stage—on the platform interface, the sanction letter, KFS, and loan agreement. Users can verify the NBFC registration status of Finagle Finance with RBI through the RBI website
1.6 In order to avail any Services being provided by FINAGLE by itself or in partnership with the LSP/DLA or other third parties it is important that YOU READ, UNDERSTAND, ACKNOWLEDGE AND UNCONDITIONALLY AGREE TO BE BOUND BY THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS POLICY OR ANY PART THEREOF, PLEASE DO NOT USE/ ACCESS/ DOWNLOAD/ INSTALL THE PLATFORM OR ANY PART THEREOF. For the users consenting to continue accessing the website of Finagle or Platform of its DLS / LSPs and avail the Services, this Privacy Policy explains our policies and practices regarding the collection, use, and disclosure of Your information.
2. COLLECTION OF INFORMATION
2.1 The collection of information under this Privacy Policy are solely for the purpose of delivering our regulated digital lending and non-lending services, in accordance with applicable Indian laws, including the RBI Digital Lending Directions, 2025 and the IT Act and Rules.
Part A: Information for Lending Services: Information collected by us or our LSP/DLA for facilitation of Loans being applied by user, credit underwriting by us, sanction and disbursed by FINAGLE.
Part B: Information for Non-Lending Services: Information collected by us or Platform of our LSP/DLS while registering a User or while providing Value Added Services (i.e. all services other than facilitation of loans).
2.2 Information we collect about you: In order to facilitate the lending and non lending services, FINAGLE will be required to access, collect and share Personal Information, financial details, reference. In such cases, FINAGLE will share the information securely and ensure that all personal information recipients comply with confidentiality, fidelity and secrecy obligations and sign covenants in this regard. FINAGLE may make information available to third parties that are financial and non-financial companies, government agencies, courts, legal investigators, and other non-affiliated third parties as requested by You or Your authorized representative, or otherwise when required or permitted by law.
2.3 User Personal Information: The data points we collect from You for both lending and non-lending services include, inter alia, your full name, email id, PAN, GST Network user id & password, address, mobile number, postal code, banking details.
2.4 Social Account Information: FINAGLE may provide you with the option to register using social accounts (Google) to access the website and shall collect only such registered email id and user public profile information like name, email depending on the platform used by You to log-into the Application during registration/ sign in process.
How we use this information: We may collect, and store email id, name and address associated with that account for the purpose of verification and to pre populate relevant fields in the course of Platform interface. However, we shall not collect / store account passwords.
2.5 Device Information and Installed Apps data: Mobile App or platform of our LSP and DLA additionally collect certain device information provided herein for our lending and non-lending services. Information which the Application collects, and its usage, depends on how you manage your privacy controls on your device.
Device Information: When you access the website, we store the information we collect with unique identifiers tied to the device you are using. We collect information from the device when you log on the website and explicitly seek permissions from You to get the required information from the device. Additionally, we also collect your Log information (via the domain server through which the User accesses the App Search queries, IP address, crashes, date etc for the purpose of improvising the Application functionality. In
addition to the above, we also track and collect the data related to the performance of the Application and other diagnostic data for identifying and resolving any technical glitches that may be identified from such data and also for improving the overall functionality of the Application.
How we use the information: We collect information about your device to provide automatic updates and additional security so that your account is not used in other people’s devices. In addition, the information provides us valuable feedback on your identity as a device holder as well as your device behaviour, thereby allowing us to improve our products interaction, quality of services and provide an enhanced customized user experience to you. We further collect other identifiable information such as your transaction’s history on the Platform when you set up a free account with us.
2.6 Location, Camera, Microphone Access: We will collect your device location and request one-time access to camera and microphone for facilitating lending services as well as providing any non-lending services only in accordance with applicable laws.
How we use this information: We shall collect your device location information for verifying your address, for the KYC and onboarding process for the Services. We may request camera access to scan and capture the required KYC documents as per our Lending policy in accordance with applicable laws. We require microphone permissions to enable a two-way communication between our authorised agents and you for the purpose of performing and completing your Video KYC for the Lending Services. Your audio shall be recorded for regulatory purpose.
2.7 Information about you we collect from third parties : For making the Services available to you, we may collect credit information by obtaining specific authorisations from you (if required under applicable laws), from certain third parties such as credit bureaus or credit rating companies as your ‘authorised representative’ from time to time in accordance with applicable laws during the loan journey as may be required by our Lending Policy.
In order to facilitate credit products to you, we may receive certain information pertaining to document verification, repayment status etc from certain third parties including NSDL, payment gateway providers. We may further collect your GST details from Official GSTIN API stack or other relevant websites using the GST Network user id and password details or OTP as provided by you.
We may further collect your bank account numbers or UPI payment information to facilitate collection and repayment of loan payments. We shall only collect this information on a need basis strictly for the purpose of providing you with the Services. The information collected from such third parties are not retained by us.
2.8 Information you give us about you: In due course of using our Services, you are required to submit data to enable our Services. We use this data to create your profile and provide you with the best available services. Mentioned below is some of the data we collect from you:
a. Data provided by you by filling in forms in the Application or on the Website.
b. Data provided by corresponding with us (for example, by e-mail or chat). c. Data and information, you provide when you register to use the Website, subscribe to any of our Services (such as applying for a loan), search for a Service, and when you report a problem with our website, our Services, or any of our Sites.
d. Data including your name, address, gender, date of birth, e-mail address, phone number, username, password and other registration information. e. PAN Card, Aadhaar Card, financial information such as employer name,
monthly salary slips, bank account no., bank statements, credit information, GST information, copies of identification documents which are required as per our Lending policy for the onboarding of your application to avail the services.
f. Data generated by your usage of our Platform
These data help us create your profiles, complete mandatory KYC as per the requirements of our Lending Policy who offer you the Services, unlock and approve loans and provide you with customized support in case of issues. Please note that we do not store any data provided by you except for the basic information such as name, address, contact details etc.
Wherever possible, we indicate the mandatory and the optional fields. You always have the option to not provide any information by choosing not to use a particular service or feature on the Platform. While you can browse some sections of our Platform without being a registered member as mentioned above, certain activities require registration and for you to provide the above details.
We under no circumstances and at no point take any biometric data from you for any of our services or operations. In case, if any of our representatives ask for the same from you, we request you to kindly refrain from doing the same and address this concern to our Grievance Officer (the details of the same have been provided below).
2.9 Storage of Personal Information: For the provision of lending Services, we shall only store basic personal information such as name, address, contact information which are required to be stored for carrying out our non-lending services. We ensure that every data or information that we collect from you is stored in servers located in India and the same is compliance with all the statutory/regulatory obligations.
2.10 Collection of Certain Non-Personal Information: We automatically track certain information about you based upon your behaviour on our Platform. We use this information to do internal research on our users’ demographics, interests, and behaviour to better understand, protect and serve our users and improve our services. This information is compiled and analysed on an aggregated basis.
2.11 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 / apps and online marketplace websites / apps. Use of this information helps Us identify You in order to make our website more user friendly. 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. We do not track users across third-party websites, nor do we allow third-party behavioural advertising tools on our lending app or website
3. PURPOSE OF COLLECTION
We shall use the information collected from you for facilitating the lending and non-lending Services for the following purposes as detailed below. We understand the importance of your information and ensure that it is used for the following intended purposes only.
The intended purpose of collecting information provided by you is to: a. Establish identity and verify the same.
b. To facilitate your KYC.
c. Troubleshoot problems, monitor, improve and administer our Platform. d. Provide our service i.e. facilitating loans to You or providing our value-added services or non-lending services to you.
e. Design and offer customized products and services offered us. f. Analyse how the Platform is used, diagnose service or technical problems and maintain security.
g. Send communications notifications, information regarding the products or services requested by You or process queries and applications that You have made on the Platform.
h. Measure consumer interest and satisfaction in our products and services and manage Our relationship with You.
i. Marketing and promotional purposes including sending you promotional SMS, Email and WhatsApp and inform you about online and offline offers, products, services, and updates.
j. Conduct data analysis in order to improve the Services / Products provided to the User.
k. Use the User information in order to comply with country laws and regulations.
l. Use the User information in other ways permitted by law to enable You to take financial services from us.
m. Resolve disputes and detect and protect us against suspicious or illegal activity, fraud and other criminal activity.
n. Customize your experience and enforce our terms and conditions.
We will use and retain only such basic personal information such as your name, contact information, address details and such other information which are necessary for the provision of Services and for such periods as necessary to provide You the Services on the Platform, to comply with our legal obligations, to resolve disputes, and enforce our agreements.
4. DISCLOSURE TO THIRD PARTIES
We will share Your information only with our third parties for facilitation of Services on the Platform. We will share the information only in such manner as described below:
4.1 We share Your information with our third-party partners in order to conduct data analysis in order to serve You better and provide Services our Platform.
4.2 We may disclose Your information, in order to enforce or apply our terms of use or assign such information in the course of corporate divestitures, mergers, or to protect the rights, property, or safety of us, our users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
4.3 We will disclose the data / information provided by a user with other technology partners to track how the user interacts with the Platform on our behalf.
4.4 We and our affiliates may share Your information with another business entity should we (or our assets) merge with, or be acquired by that business entity, or re-organization, amalgamation, restructuring of business for continuity of business. Should such a transaction occur than any business entity (or the new combined entity) receiving any such information from us shall be bound by this Policy with respect to your information.
4.5 We will disclose the information to our third-party technology or third-party data source providers.
4.6 We will share Your information under a confidentiality agreement with the third parties and restrict use of the said information by third parties only for the purposes detailed herein. We warrant that there will be no unauthorised disclosure of your information shared with third parties.
4.7 We shall disclose your KYC journey or any data with respect to the same to the relevant regulatory authorities as a part of our statutory audit process. Please note that your Aadhaar number shall never be disclosed.
4.8 We May share Your information with our third-party collection and/or recovery agency for recovery of credit facility in case of any default.
4.9 We may share your personal information with the governmental authorities, quasi-governmental authorities, judicial authorities and quasi-judicial authorities if we are acting under any duty, request or order as part of our legal obligations and in accordance with the applicable laws. By accepting this Privacy Policy, you hereby provide your consent to disclose your personal information for such regulatory disclosure.
4.10 Any disclosure to third parties is subject to the following:
a. If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request, we shall not seek your explicit consent however we shall reasonably endeavour to notify the same to you.
b. We shall take your express consent in the event we share your personal data with third parties.
c. We shall share your information with third-party only on a need basis and only for the purpose stated hereunder, as per the applicable laws. d. We shall additionally seek express consent through a separate consent for at appropriate stages of data collection, if so, required under applicable laws.
e. Usage of your information by such third parties is subject to their privacy policies. We share limited information with them, strictly to the extent required. We recommend you have a look at the privacy policies of such third parties.
5. DATA RETENTION AND DELETION
5.1 We at FINAGLE promise to protect your personal data from unauthorized access, misuse, and disclosure using the right security measures based on the type of data and how we are processing the same. We retain information about you to provide a seamless experience, to contact you in case of support required and about your account, to detect, mitigate, prevent, and investigate fraudulent or illegal activities during the course of the Services. We retain your data for as long as necessary to provide you with our services. We may also retain and use your basic personal information inter alia as name, contact number, transactional details and address details as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements which shall always be in accordance with applicable laws. Subject to this section, you may withdraw your consent for promotional offers and sharing your personal details at any pointy of time by writing us and we may delete your data upon reasonable written request for the same at any stage. However, your consent provides for servicing any loan which is already disbursed to you cannot be withdrawn to share with regulatory authorities, CIS companies our collection and recovery agents.
5.2 Your data may also be retained temporarily in backup systems to ensure disaster recovery, system restoration, or legal hold purposes, although access will be restricted, and deletion will be scheduled in accordance with our internal retention protocols.
6. LINK TO THIRD-PARTY SDK AND OTHER SITES
6.1 The Website has a link to registered third party SDKs, Application Programming Interface (API) integrations, redirections which collects data on our behalf and data is stored to a secured server. 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 as required under the applicable laws.
6.2 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.
6.3 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.
6.4 The inclusion of a link does not imply any endorsement of the third-party website, the website’s provider, or the information on the third-party website. We do not endorse, monitor, or have any control over the privacy practices, security measures, content, or terms of use of such third-party platforms. If the users submit personal information to any of those websites, such information is governed by the privacy policies of such third-party websites, and We disclaims all responsibility or liability with respect to these policies or the websites.
6.5 We strongly advise you to review the privacy policies and security practices of any third-party website or service you choose to engage with, especially before submitting any personal, financial, or sensitive data. We disclaim any responsibility or liability for any loss or damage that may arise from your use of such third-party sites, or your reliance on any information contained therein.
6.6 Use of third-party services (such as payment gateways, e-KYC vendors, or credit bureaus) via our platform is subject to additional privacy controls that will be explicitly communicated to you at the time of interaction, wherever applicable.
7. CHANGES IN THIS PRIVACY POLICY
We reserve the right to change, modify, add, or remove portions of this Privacy Policy at any time for any reason. In case, any changes are made in the Privacy Policy, we shall update the same on the Platform. Once posted, those changes are effective immediately, unless stated otherwise. We encourage you to periodically review this page for the latest information on our privacy practices. Continued access or use of the Services constitute Your acceptance of the changes and the amended Privacy Policy.
8. SECURITY PRECAUTIONS
8.1 The Platform intends to protect your information and to maintain its accuracy as confirmed by you. We implement reasonable physical, administrative and technical safeguards to help us protect your information from unauthorized access, use and disclosure. For example, we encrypt all information when we transmit over the internet. We also require that our registered third-party service providers protect such information from unauthorized access, use and disclosure.
8.2 Our Platform has stringent security measures in place to protect the loss, misuse and alteration of information under control. We endeavour to safeguard and ensure the security of the information provided by you. We use Secure Sockets Layers (SSL) based encryption, for the transmission of the information, which is currently the required level of encryption in India as per applicable law.
8.3 We blend security at multiple steps within our products with the state-of-the art technology to ensure our systems maintain strong security measures and the overall data and privacy security design allow us to defend our systems ranging from low hanging issue up to sophisticated attacks.
8.4 We aim to protect from unauthorized access, alteration, disclosure or destruction of information we hold, including:
a. We use encryption to keep your data private while in transit.
b. We offer security feature like an OTP verification to help you protect your account.
c. We review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems.
d. We restrict access to personal information to our employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
e. Compliance & Cooperation with Regulations and applicable laws.
f. We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it.
g. Data transfers.
h. We ensure that Aadhaar number is not disclosed in any manner.
8.5 Data protection laws vary among countries, with some providing more protection than others. We also comply with certain legal frameworks relating to the transfer of data as mentioned and required under the Information Technology Act, 2000, rules and the amendments made thereunder.
8.6 When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.
9. YOUR RIGHTS
9.1 Modifying or rectifying your information: In the event that any Personal Information 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. In case of modification of Personal Information, Users will be required to furnish supporting documents relating to change in Personal Information for the purpose of verification by the Company.
9.2 Your Privacy Controls: You have certain choices regarding the information we collect and how it is used:
a. Your device may have controls that determine what information we collect. For example, you can modify permissions on your Android/iOS device or Browser to remove any permissions that may have been given. However, Platform does not provide a guarantee of Services if any such controls are exercised.
b. Delete the App from your device
c. You can also request to remove content from our servers in accordance with Clause 9.3.
9.3 Withdrawal/Denial of consent: You acknowledge that the website has duly collected the information with your consent, and you have the option to not provide such information or deny consent for use of specific information or revoke the consent already given. However, any withdrawal of such personal information will not be permitted in case any Service availed by You is active. Where a consent has been withdrawn the Platform does not guarantee or be liable for providing such Service. You shall have the following rights pertaining to your information collected by us.
a. Deny Consent: You shall have the right to 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. However, any such denial will not prejudice the right of FINAGLE to retain any data in relation to the loans availed by you or by the non-lending service providers in relation to the non-lending services provided to you. Further, in case of a denial of a consent, the Platform does not provide a guarantee or will not be liable towards the continued facilitation of the Services if any such controls are exercised.
b. Withdraw Consent: You may withdraw Your consent to contact You, for the continued collection, use or disclosure of Your information, at any time, or request for deletion of your Login account by raising a request by calling on our customer support number available on your application. However, Platform does not provide a guarantee of Services if any such controls are exercised. Further, if You have availed any loan facilities from us, we shall have the right to continue processing Your information till such credit facility has been repaid in full, along with any interest and dues payable and/or for such period as may be allowed under applicable law. However, We, shall not retain Your data and information if it is no longer required by Us and there is no legal requirement to retain the same. Do note that multiple legal bases may exist in parallel, and We may still have to retain certain data and information at any time. Also, the information may still be used for execution of any outstanding or termination activity of any Lending or Non-lending Services.
9.4 Report an issue: You have a right to report a security incident. You shall be entitled to prevent unauthorised such usage of your information by our personnel/agents by informing us, within 10 days of being informed of the proposed use, that you do not wish to disclose such information.
Notwithstanding anything to the contrary stated above, the following are specific scenarios listed below which may have consequences to your withdrawal of consent.
9.5 Marketing and Communication: The consent for this information be withdrawn if You write an email to the email.
9.6 Information/data deletion may not be implemented for ongoing Services including loan, insurance policy or digital gold products.
10.GENERAL
10.1 We encourage parents and guardians of children to observe and participate in monitoring and/or guiding their online activities. We will never knowingly collect any Personal Identifiable Information from children below the age of eighteen. If you think that your child has divulged any such information on our website, we strongly urge you to contact us immediately. We assure you of prompt action in removing any such information available in our records.
10.2 As part of our loan eligibility checks and compliance with the Know Your Customer (KYC) norms prescribed by the Reserve Bank of India, we require documentary age verification at the time of onboarding. If we become aware that we have inadvertently collected personal data from a child, we will take immediate steps to delete or anonymize such data from our systems
10.3 By using our services, you affirm that you are at least 18 years of age and legally eligible to enter into a binding contract under Indian law.
10.4 This Privacy Policy shall be governed by and interpreted in accordance with the laws of India, and any disputes arising from or related to this policy shall be subject to the exclusive jurisdiction of the courts located in Delhi, India.
10.5 If any provision of this Privacy Policy is found to be invalid or unenforceable under applicable law, such provision shall be severed, and the remainder of the policy shall continue in full force and effect.
10.6 In case of any ambiguity or conflict in interpretation, the English version of this policy shall prevail. Headings are for reference purposes only and do not affect interpretation.
10.7 Nothing on our platform constitutes financial, legal, or professional advice. You should independently verify any information before relying on it and consult appropriate advisors where necessary.
10.8 We shall not be liable for any direct, indirect, incidental, consequential, or punitive damages, including but not limited to loss of profits, loss of data, or loss of business opportunities arising out of or in connection with your access or use of the platform or reliance on any material provided therein.
10.9 We do not guarantee that access to our platform will be uninterrupted, error-free, or free from viruses or other harmful components. You are responsible for implementing adequate safeguards before downloading any material from our platform
11.GRIEVANCE REDRESSAL
You may make a request for deleting any information from the Platform at any stage upon making a request to Us in the following manner:
Grievance Officer: In accordance with Information Technology Act 2000 and rules made there under, the name and contact details of the Grievance Officer are provided below for your reference:
Mr. Himanshu Gaur
Phone: +91 9026105409
Email: gro.atr@finaglenbfc.com
Timing: Monday to Friday 10 Am to 6 PM