“MPOKKET FINANCIAL SERVICES PRIVATE LIMITED” (“mPokket” “Company” “we”, “our”, “us”) is a company incorporated under the Companies Act, 2013 bearing CIN No. U65999WB2019PTC233120, having its registered office at PS Srijan Corp. Park, Unit-1204, Tower-I Plot-G2, Street No 25, GP Block, Sector V Kolkata -700091. Mpokket Financial is a registered non-banking financial company having a certificate of registration issued by the Reserve Bank of India (“RBI”) and is engaged in the business of providing unsecured personal loans and services through technology platforms such as Mobile/ Smartphone Applications. The mPokket App is owned, operated and made available by Maybright Ventures Private Limited (hereinafter referred to as “MVPL”), having its registered office at PS Srijan Corp. Park, Unit-1204, Tower-I Plot-G2, Street No 25, GP Block, Sector V Kolkata -700091, India.
This Privacy Policy is an electronic record in the form of an electronic contract formed under the Information Technology Act, 2000 and the rules made thereunder and the amended provisions pertaining to electronic documents / records in various statutes as amended by the Information Technology act, 2000. The term “you”, “customer” “user”, “borrower” denotes the person who avails the services of mPokket by using the mobile application. In order to provide you with the Services, process your loan requests, and to ultimately provide a loan to you, we and MVPL need to collect various data and information from you. The manner in which this data and information is collected, retained, shared, stored, and processed by us (i.e., Company) and MVPL is addressed in this Privacy Policy/ Privacy Statement (“Policy”).
We may revise this Policy as well as update the Services and the App from time to time, It is strongly recommended for you to return to this page periodically to review the most current version of this Privacy Statement which is amended by us from time to time. If you do not agree with any part of this Policy, please stop using our Services immediately.
This Policy, incorporates, and includes our Terms and the Agreement(s) executed by you for availing the lending products made available by us (“User Loan Agreement”). Words and phrases not defined in this Policy shall mean the same as provided in the Terms. We comply with all regulations on the protection of Personal Information specified in laws and regulations applicable to information and communication service providers.
By using the App, you consent to provide mPokket, your data in the ways listed below. mPokket collects the data you provide to ensure that you are provided with the Services in the best manner possible. We use this data to underwrite (i.e. assess the risk it will be taking) loan we might offer you and to determine the rates and tenure for such loans. The data being asked from you helps us to provide services to you in a robust and user-friendly manner.
We have detailed the manner in which data will be collected:
When You visit mPokket Website, the administrator processes technical data such as Your IP-address, Device ID or MAC-address, information about the manufacturer, model, operating system of Your mobile device, the internet browser you use to enable us to deliver the functionalities of the Website. In addition to this, in certain instances the browser may prompt you for your geo-location to allow us to provide you with an enhanced experience. With this technical data the Website administrator can manage the Website, for instance by resolving technical difficulties or improving the accessibility of certain parts of the Website. This way, we ensure that You can (continue to) find the information on the Website in a quick and simple manner.
We and MVPL collect the data you provide to us when you create or update your mPokket account. This includes your full name, phone number, email ID, gender, photograph, marital status, PAN, verifies Aadhaar Number linked with your Mobile Number, date of birth, pin code, nature of employment, official employment email address, name of employer, monthly income. We or MVPL may require you to share further information on a later date to confirm the veracity of your information or pursuant to any additional features added to the App.
We and MVPL use this data provided by you for enabling the App and its Services for a. Loan Processing and KYC Authentication, b. For Enabling Customer Support, c. For Research and Development, d. For Enabling Communications Between You and Us, e. For enabling Marketing and Outreach f. For Automated Decisions, g. For Legal Compliance and Requirements.
We and MVPL may also be working closely with third parties (including, for example, credit information bureaus, business partners, technical sub-contractors, analytics providers, Lending service providers) and may lawfully receive information about you from such sources. Such data may be shared internally and combined with data collected on the App.
How we and use this data: For Enabling the App and its Services; For Loan Processing and KYC Authentication; For Enabling Customer Support; For Research and Development; For Enabling Communications Between You and Us; For enabling Marketing and Outreach; For Automated Decisions; For Legal Compliance and Requirements
How we and use this data: For Enabling the App and its Services; For Loan Processing and KYC Authentication; For Enabling Customer Support; For Research and Development; For Enabling Communications Between You and Us; For enabling Marketing and Outreach; For Automated Decisions; For Legal Compliance and Requirements.
The data that is collected in accordance with Section 1 above will be used in the manner detailed below:
The data collected is used to personalize, maintain and improve our Services. This includes using the data to:
We use the data to analyze your creditworthiness, loan eligibility, KYC documents, current employment verification and the terms of your loans. While MVPL collects the Financial and KYC Information, we are required to individually process the loan requests and verify the KYC documentation received. Failing to process such data means that you cannot be provided any loans. You hereby grant us explicit consent to fetch your KYC (Know Your Customer) details from the Central KYC Records Registry using the details provided by you. We also use the data to track disbursement and repayment of your loan.
MVPL uses the information to provide customer support, including to resolve your concerns from the use of the Services, and train customer service executives.
The data so collected by us may be used for research, analysis, and product development to improve the UI/UX experience – all of which will ultimately improve how you experience the App. This also helps MVPL develop automated actions to be triggered in certain events, such as to identify if photographs uploaded are not clear, fraud takes place, IFSC is incorrect etc.
MVPL may add features that allow you to call us (through the App or otherwise), similarly, MVPL may also need to contact you (through the App or any other channels that you give us access to, such as WhatsApp).
MVPL may use the data collected to market the App and its Services. This includes sharing your feedback, ratings and screen names for purely promotion and marketing purposes. Such promotion and marketing may be done via hoardings, banners, pamphlets etc.
The App may provide automated features for customer responses, reimbursement tracking, etc. As the App grows, MVPL will keep adding more automated features to the App.
We process your data to meet the requirements of applicable laws, regulations, standards, rules, codes and the requirements as may be applicable on non-banking financial institutions and other codes with which company must comply. This includes:
We may use the data we collect to investigate or address claims or disputes relating to use of our Services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
MVPL may use the data collected to offer new products and services for your use.
Personal information held by us will only be used for purposes directly related to one or more legitimate functions or activities in the provision of our services or as otherwise permitted by law. We are very protective about your data. We may enter into data-sharing agreements as Non-Disclosure Agreements or disclose the collected data in order to provide the Services and new product offerings to you. We have detailed the manner in which we and MVPL share the collected data below.
The security of your Personal Information is very crucial to us. It is our endeavour to protect your Personal Information against any type of unauthorized usage. To do this we take all reasonable steps to ensure personal information is protected from misuse, loss and unauthorised access, modification or disclosure in accordance with statutory requirements. This includes having security measures and controls in place to protect personal information including limiting access, cryptography, physical and environmental security and audit monitoring.
The transfer of personal data between your end device and MVPL is generally carried out via best-in-class encryption protocols. If you communicate with us by e-mail, access by third parties cannot be ruled out. In the case of confidential information, we recommend using the mail, i.e., post or encrypted email communication (PGP).
Users have the right, at any time, to know whether their personal information has been stored and can consult us to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for transformation into anonymous format or to block any data. It is important for us that you remain in control of your data. Please write to us at [email protected] if you wish to exercise any of your rights under the Policy. You shall have the following rights:
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.
You have the right to withdraw your consent to this policy by uninstalling the App. However, if you have availed any loans from us, we shall have the right to continue processing your information till such loan has been repaid in full, along with any interest and dues payable. We hold your information in electronic form and will destroy or de identify personal information when it is no longer required or when we are no longer required by law to retain it (whichever is the later).
Marketing opt-outs: We may email and notify 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 receipts for amount remittance etc
Push Notifications: 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.
We process your Information only when we have obtained your consent in the manner provided hereunder. For collecting, processing (including using and storing), disclosing or sharing your Personal Information as described in this Privacy Statement, we hereby through this Privacy Statement, seek your consent and give you a notice regarding collecting, processing (including using and storing), and sharing your Personal Information for one or more of the purposes detailed herein. For any purposes, where, as per applicable laws of India, a specific consent is required, we will seek such specific consent from you from time to time.
In relation to information obtained by third parties or group entities, we rely on the consent taken by these parties on their respective platforms in our favour for us to process the information.
you may, of course, decline to share certain information with us. If you do not agree with any of the terms of this Policy or the Terms or wish to restrict disclosure of your information to third parties, make the app delete/ forget your data or revoke any consent you have provided to us and/or MVPL, please write to us at [email protected]. However, please note that if you wish to revoke any mandatory permissions or revoke the consent to process and store information such as your mPokket Account data, Financial and KYC Information and/or any other information needed to facilitate your loan amounts, in which case we may not be able to provide to you some or all of the features and functionalities of the Websites/ Apps. This may also affect our ability to process your Personal Information and may therefore lead to the non-availability or discontinuation of the services for which such Personal Information are to be used or was being used, at our sole discretion.
We and MVPL shall retain the information you provide to facilitate your smooth and uninterrupted use of the App, and (i) to provide, improve and personalize the Services; (ii) to contact you about your account and give customer service; (iii) to personalize our advertising and marketing communications; and (iv) to prevent, detect, mitigate, and investigate fraudulent or illegal activities. We and MVPL do not retain your personal data for longer than required for the purpose for which the information may be lawfully used. For any other information, we may entertain your request for deletion, however, you may not be able to use our Services at all after such deletion.
We may store your Personal Information for as long as the same is required for the fulfilment of purposes for which we collected it. The retention of Personal Information by us is determined by considering compliance with legal (contractual, statutory or regulatory requirements), accounting and compliance reporting requirements. For instance:
A. Your documents and information shall be retained by us for a period of ten years from the data of transaction.
Our Services are not directed to children, and we do not knowingly solicit or collect personal information from persons under the age of 18 (eighteen). If we find out that a child has given us personal information, we will take steps to delete that information and terminate the relevant mPokket Account.
This Privacy Statement may change or be amended over time. The recent version of this Privacy Statement is published on our Website or App, as the case may be. Please revisit this page periodically to stay aware of any changes to this Privacy Statement. We will notify you of any material changes to this Privacy Statement by publishing the same on our Website or App as applicable. Your continued use of our services confirms your acceptance of this Privacy Statement, as amended. If you do not agree to the terms and conditions as contained in our Privacy Statement, as amended, you must stop using our services and notify us.
It is very important that any Personal Information we hold about you is up to date and correct. Please inform us of any changes to your Personal Information.
We and MVPL may from time to time contact you via calls, SMS, emails, and other communication channels to provide you with information pertaining to our Services, notifications on updates vis-à-vis our Services (when we consider it necessary to do so), educational information and promotions. MVPL may also notify you if MVPL needs to temporarily suspend the App for maintenance, and keep you informed on security, privacy, or administrative-related communications. By setting up an account on mPokket, you consent to us contacting you via call, SMS, push notifications, or through any other communication channel, as we may deem fit.
We are happy to address any of your queries, concerns or questions relating to processing (including storing and using) of your information which you can raise by writing to us at [email protected].
You may address any complaints or discrepancies in relation to the processing of your Personal Information to:
– PS Srijan Corporate Park, Unit 1204, Sector V, Kolkata – 700091
We may occasionally update this Policy. Use of our Services after an update constitutes consent to the updated notice to the extent permitted by law. Please take the time to periodically review this Policy for the latest information on our privacy practices.