PRIVACY POLICY
Clickredit(com.clickredit.loan)
This Privacy Policy document (“Privacy Policy”) is published in accordance with the provisions of Rule 4 (1) of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 which requires the publishing of a privacy policy for handling of or dealing in personal information including sensitive personal data or information.
By visiting the Clickredit mobile and/or web application (the “App”) (collectively, the “Platform”) and availing the services provided by us (“Services”) you agree to be bound by the terms and conditions of this Privacy Policy.
By mere access to the Platform or any part thereof, you signify your assent to this Privacy Policy and consent to the processing of your personally identifiable information (Personal Information, Sensitive Personal Data or Information) to Yashik Finlease Pvt LtdD(“we” or “our” or “us” or “Clickredit”). This Privacy Policy is incorporated into and subject to the Terms of Use of the Platform.
For the purpose of this Privacy Policy, the users of the Services may be customer/applicant / borrower/ consumers, or any other persons using Services or accessing our Platform (“user” or “you” or “your”).
To better understand your identity and ensure that your users meet their credit needs. Therefore, before you submit your application, we need your authorization to collect "Contact" and "SMS" Information, and upload them to "https://api.clickredit.in". We are committed to using secure data transfer protocol to encrypt data and ensure the security of information. Please feel free to use. If you do not agree, we will not perform this operation, and the application will not be able to provide normal service for you and exit Application.
《 COLLECTION OF FINANCIAL SMS INFORMATION 》
We collect all your SMS data but only monitor your messages related to financial transactions. To be specific, we will monitor the name of the sender, the description and the amount of transaction to perform credit risk assessment. This enables faster and quicker loan disbursal. No personal SMS data is monitored, read, stored or shared.The Financial SMS will be uploaded to "https://api.clickredit.in". We will delete the Financial SMS after we have determined your risk profile.
《 COLLECTION OF Call Records 》
In order to ensure that real users use the app in a normal environment, rather than using a simulator for fraudulent behavior,we need to obtain your call records,including phone number,name and call time. The call records information will be uploaded to "https://api.clickredit.in"，and will not be shared with third parties.
《 COLLECTION OF USER PERSONAL INFORMATION 》
When you use our Platform, we collect and store your information which is provided by you from time to time by
explicitly seeking permissions from YOU to get the required information. Our primary goal in doing so is to
provide you a safe, efficient, smooth and customized experience and Services. This allows us to provide services
and features that meets your needs, and to customize our Platform to make your experience safer and easier and
to improve the Services provided by us. More importantly, we collect personal information from you that we
consider necessary for achieving the aforementioned purpose.
In general, you can browse the Website or App without telling us who you are or revealing any information about
yourself. However, to create an account on the Platform, you must provide us with certain basic information
required to provide customized services. The information we collect from you, inter alia, includes:
1. your full name;
2. email;
3. gender;
4. photograph;
5. mailing address;
6. postal code;
7. emergency contact;
8. university/college details;
9. phone number;
10. National Identity Card (NIC);
11. Academic records and certificates.
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. We also collect user
account data which includes email address and user public profile information like name, photo, ASID depending
on the social media or networking platform used by You like Google or Facebook to log-into an app. This
information is required as a part of registration process to access our Service, and it is also used to
auto-populate relevant fields in the course of the interface of the App. We further collect other identifiable
information such as your transactions' history on the Platform when you set up a free account with us as further
detailed below. While you can browse some sections of our Platform without being a registered member as
mentioned above, certain activities (such as availing of loans from the third party lenders on the Platform)
require registration and for you to provide the above details. The Platform will clearly display the personal
information it is collecting from you, and you have the option to not provide such personal information.
However, this will limit the services provided to you on the Platform.
Our app also collects mobile number for verification to check the active SIM status on the device, uniquely
identify you and prevent frauds and unauthorised access.
As a part of our Video Know Your Customer (Video KYC) process, collection of your personal information has
become mandatory to ensure the completion and authentication of your KYC. In this regard, permissions for
microphone, camera will be mandatory required.
We use the collected data for various purposes:
• To provide and maintain the Service
• Verify your identity and contact details
• To notify you about your transactions & changes to our Service
• Contact you and update you on the performance of our Services
• Communicate with you and process your requests
• Offer surveys, promotions, and marketing communications
• Contact supplied personal references to verify accuracy of information and coordinate as to the identity and
personal circumstances of the client
• To Provide funds transfer services and related services
• To provide customer care and support
• To monitor the usage of the Service
• To detect, prevent and address technical issues
• Provide electronic funds transfer services and related services
• Collection of delinquent accounts
《 LINK TO THIRD-PARTY SDK 》
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 ourselves /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.
《 COLLECTION OF DEVICE LOCATION AND DEVICE INFORMATION 》
We collect and monitor the information about the location of your device to provide serviceability of your loan
application, to reduce risk associated with your loan application and to provide pre-approved customised loan
offers. This also helps us 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.
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 services
and provide an enhanced customized user experience to you.
《 COLLECTION OF INSTALLED APPLICATIONS 》
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.
《 COLLECTION OF INSTALLED APPLICATIONS 》
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.
《 CAMERA 》
We require camera access to scan and capture the required KYC documents thereby allowing us to auto-fill
relevant fields.
As a part of our KYC journey, we require access to your camera to enable you to initiate your KYC process. This
permission allows us or our authorised agents to perform your Video KYC while also taking screenshots of your
original Officially Verified Documents that you present during your Video KYC journey. Video KYC enables you to
complete your KYC digitally, smoothly and efficiently. Your video shall be recorded and retained for regulatory
purpose along with screenshots of original Official Verified Documents.
《 PHONE STATE 》
Collect and monitor specific information about your phone like your phone's unique device identifier, user profile information as this information helps us in uniquely identifying a user, so that we can detect and prevent any unauthorized device from acting on your behalf. This enables us to detect fraud and manage risks better.
《 COLLECTION OF OTHER 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. We also collect your Internet Protocol (IP) address and the URL used by you to connect your computer to
the internet, etc. This information may include the URL that you just came from (whether this URL is on our
Website or not), which URL you next go to (whether this URL is on our Website or not), your computer browser
information, and your IP address.
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 get a loan through the Platform, we collect information about your applying behavior.
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.
《 USE AND DISCLOSURE OF YOUR PERSONAL AND OTHER INFORMATION 》
We understand the importance of your information and ensure that it is used for the intended purpose only. We
access, store and use the information we collect from you in accordance with the applicable laws to provide our
Services, to research and develop new ones subject to the limitations set out in this Privacy Policy.
We use the information to:
1. resolve disputes;
2. troubleshoot problems;
3. help promote a safe service;
4. analytical analysis;
5. marketing purposes;
6. measure consumer interest and satisfaction in our products and services;
7. inform you about online and offline offers, products, services, and updates;
8. customize your experience;
9. detect and protect us against suspicious or illegal activity, fraud and other criminal activity;
10. enforce our terms and conditions;
11. improvement of our services and as otherwise described to you at the time of collection;
12. In our efforts to continually improve our product and service offerings, we collect and analyze demographic
and profile data about our users' activity on our Platform.
《 PURPOSE OF COLLECTING INFORMATION 》
The intended purpose of collecting information provided by you is to:
1. establish identity and verify the same;
2. to complete your Video KYC;
3. monitor, improve and administer our Platform;
4. provide our service i.e. perform credit profiling for the purpose of facilitating loans to You;
5. design and offer customized products and services offered by ourselves /our third party financial
partners;
6. analyse how the Platform is used, diagnose service or technical problems and maintain security;
7. send communications notifications, information regarding the products or services requested by You or process
queries and applications that You have made on the Platform;
8. manage Our relationship with You and inform You about other products or services We think You might find of
some use;
9. conduct data analysis in order to improve the Services / Products provided to the User;
10. use the User information in order to comply with country laws and regulations;
11. conduct KYC for ourselves /our third party lending partners based on the information shared by the User;
12. use the User information in other ways permitted by law to enable You to take financial services from our
lending partners.
13. We will use and retain the information 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.
《 DISCLOSURE TO THIRD PARTIES 》
We will share Your information with only our registered third parties including our regulated financial partners
for provision of Services on the Website/ App. We will share Your information with third parties only in such
manner as described below:
1. We disclose and share Your information with ourselves /our third party partners for facilitation of a loan or
facility or line of credit or applying a loan;
2. We share Your information with ourselves /our third party partners in order to conduct data analysis in order
to serve You better and provide Services our Platform;
3. We may disclose Your information, without prior notice, if we are under a duty to do so in order to comply
with any legal obligation or an order from the government and/or a statutory authority, or 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. We will disclose the data / information provided by a User with other technology partners to track how the
User interact with the Platform on Our behalf.
5. 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.
6. We will disclose the information to ourselves /our third party technology and credit partners to perform
credit checks and credit analysis like Credit Bureaus or third party data source providers;
7. 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.
8. By using the Platform, you hereby grant your consent to the Company to share/disclose your Personal
Information (i) To the concerned third parties in connection with the Services; and (ii) With the governmental
authorities, quasi-governmental authorities, judicial authorities and quasi-judicial authorities, in accordance
with applicable laws of Sri Lankan.
9. We shall disclose your Video KYC journey to the relevant regulatory authorities as a part of our statutory
audit process. Please note that your NIC number shall never be disclosed.
10. In case we use or disclose your information for any purpose not specified above, we will take your explicit
consent.
《 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.
《 ACCESSING YOUR INFORMATION / CONTACTING US 》
At any point of time Users can choose to edit/modify or delete/withdraw any Personal Information shared for use of the Platform. Please note that deleting or withdrawing information may affect the Services we provide to you. 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.
《 YOUR PRIVACY CONTROLS 》
You have certain choices regarding the information we collect and how it is used:
1. Device-level settings: 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.
2. Delete your entire App account.
3. You can also request to remove content from our servers based on applicable law or by writing to our
Grievance Officer.
《 SECURITY PRECAUTIONS 》
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.
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 Sri Lankan as per applicable law.
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.
In addition, the Website and App have been certified for the following security certifications:
1. 9001: being the international standard that details requirements for a quality management system (QMS).
Organizations use the standard to demonstrate the ability to consistently provide products and services that
meet customer and regulatory requirements with the requisite security protections.
2. 27001 (formerly known as /IEC 27001:2005): is a specification for an information security management system
(ISMS) and is the suggested level of certification required under the Information Technology Act, 2000. An ISMS
are a framework of policies and procedures that includes all legal, physical and technical controls involved in
an organization’s information risk management processes.
3. 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 NIC number is not disclosed in any manner.
i. We or our affiliates maintain your information on servers located in Sri Lankan. 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 and rules
made thereunder
j. 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.
《 LINKS TO OTHER SITES 》
Our Platform links to other websites that may collect information about you. We are not responsible for the privacy practices or the content of those linked websites. With this Policy we’re only addressing the disclosure and use of data collected by Us. If You visit any websites through the links on the Website, please ensure You go through the privacy policies of each of those websites. Their data collection practices, and their policies might be different from this Policy, and We do not have control over any of their policies neither do we have any liability in this regard.
《 YOUR CONSENT 》
By using the Platform and by providing your information, you consent to the collection, sharing, disclosure and
usage of the information that you disclose on the Platform in accordance with this Privacy Policy.
If we decide to change our Privacy Policy, we will post those changes on this page so to make you aware of the
information we collect, how we use it, and under what circumstances we share and disclose it.
《 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:
Company Name: Yashik Finlease Pvt Ltd
Address: Calzada de los Jinetes No. Exterior 107, Floor 2, Colonia Las Arboledas, cp 54026, Tlalnepantla State of Mexico
Email: grievance@clickredit.in
Service Number: 7716764348
Time: Mon - Sat (10:00 - 19:00)