Last updated on 20 March, 2023
QFI Technologies Private Limited, CIN No. U74999KA2021PTC145339 (“Company”, "We", "Us", or "Our"), a private limited company with its registered office at #17/1, Bharat Apartments, 44/1 Fair Field Layout, Race Course Road, Bangalore – 560001, Karnataka, India which owns and operates the website www.niro.money and/or the mobile application ‘the Niro App’ (collectively referred to as the “Platform”) is committed to protecting Your privacy and the information that You share while using the Platform. We value the trust You place in Us. That’s why, We maintain the highest security standards for securing the transactions and Your information.
1. Collection of Information
We collect Personal Information (defined below) from You when You register or set up an Account with Us or avail a financial product on the Platform. You may browse certain sections of the Platform without being registered with Us. However, to avail certain Services on the Platform You are required to set up an Account with Us.
We may also ask You for certain financial information, including Your bank account details and type, Indian financial system code (IFSC) of bank, and/or other necessary payment related details or other payment method data, and debit instructions or other standing instructions including NACH mandate to process the Services, including facilitating disbursement and repayments towards the availed financial products through the Platform. We may ask You to provide certain additional information about Yourself on a case-to-case basis. All information disclosed by You shall be deemed to be disclosed willingly and without any coercion. No liability pertaining to the authenticity / genuineness / misrepresentation / fraud / negligence of the information disclosed shall lie on the Company nor will the Company be in any way responsible to verify any information obtained from You.
The above information is collectively referred to as (“Personal Information”).
KYC related information: We may retrieve from Your records available with third party including from Know Your Customer (KYC) Registration Agency (KRA) such as name, KYC details, KYC status, father’s/spouse’s name, occupation, address details and other related documents, for completion of Your KYC, which is required by the financial institutions for processing of Your application for availing a financial product.
Location based information: When and if You download and/or use the Platform through Your mobile, We explicitly seek permissions from You to get the required information from the device. We may receive information about Your location, Your IP address, and/or Your mobile device, including a unique identifier number for Your device and such other information as may be required for onboarding You on the Platform (through a one-time permission to access and process such information at the time of onboarding and KYC collection). In addition to the above, We identify and use Your IP address to also help diagnose problems with Our server, resolve such problems and administer the Platform. Your IP address is also used to help identify You and to gather broad demographic information.
Access to Camera and Microphone: We require a one-time access to Your camera to scan and capture the required KYC documents thereby allowing Us to auto-fill relevant fields. As a part of facilitation of the KYC process, We require a one-time access to Your camera to enable You to initiate Your KYC process. This permission allows Us or Our authorized agents to perform Your video KYC while also taking screenshots of Your original officially verified documents that You present during Your video KYC. Video KYC enables You to complete Your KYC digitally, smoothly, and efficiently. Your video shall be recorded and retained for regulatory purposes along with the screenshots of original official verified documents. We require a one-time microphone permission to enable a two-way communication between Our authorized agent and You for the purpose of performing and completing Your video KYC. Your audio shall be recorded for regulatory purposes.
Access to storage: 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 financial product application details filling and disbursal process. This ensures that You are provided with a seamless experience while using the Platform. This is a one-time request and the same would be obtained at the time of sign up.
Non–Personal and Automatic Information: We may also collect certain non-personal information, such as system generated user ID and access tokens (“Non - Personal Information”), while You browse, access or use the Platform or have the Niro App installed on your mobile device. We receive Non–Personal Information by the use of data collection devices such as “cookies” on certain pages of the Platform, in order to help and analyze Our web - page flow, track user trends, and promote trust and safety. We place both permanent and temporary cookies in Your computer’s hard drive.
User communications: If You choose to post messages on Our message boards, chat rooms or other message areas or leave feedback, We will collect and store such information You provide to Us. We retain this information as necessary to resolve disputes, provide customer support, respond to queries, and inquires, and troubleshoot problems and improve the Services. If You send Us correspondence, such as emails or letters, or if other users or third parties send Us correspondence about Your activities or postings on the Platform, We may collect and retain such information into a file specific to You for responding to Your request and addressing concerns in relation to Your use of the Platform.
All financial information gathered by the Company shall be stored on servers, log files and any other storage system owned by the Company or by third parties in India, and such storage will be need-based and to the extent required to render Services.
Our primary goal in doing so is to provide You a safe, efficient, smooth, and customized experience on the Platform. The information collected allows Us to provide the Services and features on the Platform that most likely meet Your needs, and to customize the Platform to make Your experience safer and easier. More importantly, while doing so, We collect the above - mentioned Personal Information from You that We consider necessary for achieving this purpose.
As a matter of principle, we do not collect certain special categories of Personal Information about You such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, information about your health or any genetic information.
We also do not voluntarily or actively collect, use or disclose Personal Information of minors according to the minimum age equivalent in the relevant jurisdiction, without the prior consent of the parents or guardians of the minor. If we learn that We have collected the Personal Information of a minor, without first receiving a verifiable parental consent, we will take steps to delete the information in a manner consistent with applicable laws of India as soon as possible.
We may obtain some of Your information including Personal Information from third parties, or from publicly available sources. The third parties from who We obtain Your information include Our business partners, independent service providers, Our group entities, various merchants, marketplaces, re-sellers, banks, payment partners, payment aggregators, payments systems, payment service providers, financial institutions and from credit reference agencies and credit bureaus on Your behalf etc. You hereby provide Your unconditional consent for us to do so subject to the applicable law for the time being in force.
In general, You can browse the Platform without telling Us who You are or revealing any Personal Information about Yourself. In such a case, We will only collect and store the Non – Personal Information. Once You give us Your Personal Information, You are not anonymous to Us. Wherever possible, while providing the information to Us, We indicate which fields are mandatory and which fields are optional for You. You always have the option to not provide the Personal Information to Us through the Platform by choosing to not use a particular Service or feature being provided by Us on the Platform, which requires You to provide such information. We may automatically track certain information about You based upon Your behaviour on the Platform. We use this information to do internal research on Your demographics, interests, and behaviour to better understand, protect and serve You. This information is compiled and analyzed by the Company on an aggregated basis and not individually, in a manner that does not specifically identify You.
2. Use of information:
We use the Personal Information, other information and Non-Personal Information, for the following:
- to create Your login credentials or establishing Your Account;
- to provide and improve the Services and features on the Platform that You request;
- to resolve disputes and troubleshoot problems;
- to help promote a safe service on the Platform and protect the security and integrity of the Platform, the Services and the users;
- to inform You about online and offline offers, products, services, and updates;
- to customize Your experience on the Platform or share marketing material with You;
- to detect, prevent and protect Us from any errors, fraud and other criminal or prohibited activity on the Platform;
- to enforce and inform about Our terms and conditions;
- to process and fulfil Your request for Services or respond to Your comments, and queries on the Platform;
- to contact You;
- to allow Our business partners including partnered financial institutions and/or associates to present customized messages to You;
- to communicate important notices or changes in the Services provided by the Company, use of the Platform and the terms which govern the relationship between You and Us; and
- for any other purpose after obtaining Your consent at the time of collection.
You also specifically agree and consent to Us collecting, transferring, and sharing information (including Personal Information) related to You with third parties such as with entities registered under applicable laws, with payment gateways/collecting banks/KRAs etc., solely for providing Services to You including processing Your transaction requests for the Services. The list of third parties with whom We share Your information is available at here. We will take Your specific consent in case We wish to share Your information with any other third party and update the aforementioned list.
We may occasionally ask You to complete optional online surveys. These surveys may ask You for Your contact information and demographic information (like zip code, age, or income level). We use this information to tailor Your experience at the Platform, providing You with content that We think You might be interested in and to display content according to Your preferences. We use Your Personal Information to send You promotional emails, however, We will provide You the ability to opt-out of receiving such emails from Us. If You opt out, the Company may still send You non-promotional emails, such as emails about the Services and Your Account on the Platform. Unless and until, You explicitly give Your consent to Us, to do so, We will not share Your Personal Information with another user of the Platform and vice versa.
3. Access and Sharing of Information:
Access to Your Personal Information will be provided to certain of Our employees strictly on a need-to-know basis. We may also disclose Your Personal Information to third party vendors, partnered financial institutions, consultants, and other service providers who work for the Company or provide Services through the Platform and are bound by contractual obligations to keep such Personal Information confidential and use it only for the purposes for which We disclose it to them You agree and explicitly consent to disclosure of Your Personal Information to such third-parties. This disclosure may be required for Us, for instance, to provide You access to Our Services including for undertaking credit assessment by the partnered financial institutions, processing loan or line of credit or rentpay later or any other financial product related applications by the partnered financial institutions, and processing payments including validation of Your bank accounts and Account information, to facilitate and assist Our marketing and advertising activities/initiatives, for undertaking auditing or data analysis, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to Our Services. We do not disclose Your Personal Information to third parties for their marketing and advertising purposes without Your explicit consent.
The Company may disclose Your information, to the extent necessary: (i) to comply with applicable laws and to respond to lawful requests and legal process, (ii) to protect the rights and property of the Company, Our users, and others, including to enforce the Terms, and (iii) in an emergency to protect the personal safety and assets of the Company, the users, or any person. In such an event the Company is in no manner responsible for informing You or seeking Your approval or consent.
We may, in compliance with applicable laws, share/transfer/assign all of Your Personal Information and other information with any other business entity(ies), in the event of a merger, sale, re-organization, amalgamation, joint ventures, assignment, restructuring of business or transfer or disposition of all or any portion of Our business.
4. Security Precautions and Measures:
Our Platform has reasonable security measures and safeguards in place to protect Your privacy and Personal Information from loss, misuse, unauthorized access, disclosure, destruction, and alteration of the information in compliance with applicable laws. Further, whenever You change or access Your Account on the Platform or any information relating to it, We offer the use of a secure server. We cannot however ensure or warrant the security of any information You transmit to the Company or guarantee that Your Personal Information and/or other Non-Personal Information provided for availing the Services or Platform may not be accessed, disclosed, altered, or destroyed by a breach of any of Our security measures and safeguards. In the event of any actual or suspected security incident, including data breach, We will take all measures required to be undertaken under applicable laws. It is further clarified that You have and so long as You access and/or use the Platform (directly or indirectly) the obligation to ensure that You shall at all times take adequate physical, managerial, and technical safeguards, at Your end, to preserve the integrity and security of Your data which shall include and not be limited to Your Personal Information.
5. Links to Other Third – party Sites and collection of information:
6. Public Posts:
You may provide Your feedback, reviews, testimonials, etc. on the Platform on Your use of the Services provided by the Company (“Posts”). Any content or Personal Information and Posts that You share or upload on the publicly viewable portion of the Platform (on discussion boards, in messages and chat areas, etc.) will be publicly available, and can be viewed by other users. Your Posts shall have to comply with the conditions relating to Use of Platform as mentioned in the Terms. The Company retains an unconditional right to remove and delete any Post or such part of the Post that, in the opinion of the Company, does not comply with the conditions in the Terms. The Company reserves the right to use, reproduce and share Your Posts for any purpose. If You delete Your Posts from the Platform, copies of such Posts may remain viewable in archived pages, or such Posts may have been copied or stored by other Users.
Withdrawal of consent: You may choose to withdraw Your consent (including regarding processing of data by Us or by any third party or regarding data retention) provided hereunder at any point in time. Such withdrawal of the consent must be sent in writing to firstname.lastname@example.org. In case You do not provide Your consent or later withdraw Your consent, We request You not to access the Platform and use the Services and also reserve the right to not provide You any Services on the Platform. In such a scenario, the Company may delete Your information (personal or otherwise) or de-identify it so that it is anonymous and not attributable to You.
Correcting inaccuracies in the information: You may correct or update any information online. In the event of loss of access details, You may retrieve the same or receive new access details by sending an e-mail to: email@example.com.
Right to Erasure: This is also known as ‘the right to be forgotten’ and, in simple terms, enables You to request the deletion or removal of Your Personal Information where there’s no compelling reason for Us to keep it. Such right of erasure can be exercised by writing to Us at firstname.lastname@example.org. This is not a general right to erasure; there are exceptions, such as when the law requires Us to retain certain personal information about You or where such retention is required for providing Our services to You, etc.
8. Data Retention and Deletion
|Type of Data||Data Retention Period|
|Personal Information||End of Your relationship with Us + 3 years|
|KYC-related information||End of Your relationship with Us + 3 years|
|Information generated through one-time access to camera and microphone||End of Your relationship with Us + 3 years|
|Location-based information||End of Your relationship with Us + 90 days|
|Information generated through one-time access to storage||End of Your relationship with Us + 3 years|
|Non-personal and Automatic Information||As required under applicable laws|
|User Communications||End of Your relationship with Us + 3 years|
However, We may retain information related to You if We believe it may be necessary to prevent fraud or future abuse, to enable Us to exercise Our legal rights and/or defend against legal claims or if required by law or for other legitimate purposes. When the retention period for Your Personal Information, KYC-related information, information generated through one-time access to camera and microphone as outlined above expires, We will actively destroy/delete such Personal Information and other information from Our systems.
We will comply with the following procedure for destruction and disposal of Your Personal Information and other information:
IT department is responsible for deleting or destroying electronic records. This includes ensuring that the Personal Information and other information is permanently removed and from company system and destroyed.
No Personal Information and other information that are currently involved in, or have open investigations, audits, or litigation pending shall be destroyed or otherwise discarded.
When retention requirements have been met, Personal Information and other information shall be immediately destroyed.
The authorized methods of destruction for non-electronic Personal Information and other information are shredding.
We may, however, continue to retain Your Personal Information in anonymized form for analytical and research purposes.
9. Grievance Officer:
If You have any grievance with respect to the Platform or the Services, You may write to the grievance officer, the name and contact details have been provided below:
Name: Sankalp Mathur
Address: #17/1, Bharat Apartments, 44/1 Fair Field Layout, Race Course Road, Bangalore – 560001, Karnataka, India