1. Introduction
This policy sets out the rules that must be followed in order to protect the privacy or personal identifiable information of ValuEnable, its customers, employees and, third parties or any other entities (if applicable) and to perform any action with regards to personal data, whether in whole or in part, such as collecting, recording, organizing, storing, modifying, using, disclosing, transferring, monitoring or deleting.
2. Scope
- This policy applies to all personal information or as hereby defined as Personal Identifiable Information (PII) collected, processed or stored by ValuEnable through direct data collection from subjects and through information processing systems.
- Any deviation to this policy shall be handled as per the information security exception handling process.
- The IS team shall be consulted, wherever required, to ensure appropriate and effective implementation of these controls.
- Any change to be initiated with regard to this Policy or its implementation shall be done in accordance with ValuEnable policies.
3. Responsibilities
It is the responsibility of the below teams/functions to implement and maintain the controls defined in this policy.
- Board of Directors
- Respective Department Heads
- CISO
- Legal & Compliance Team
- All Employees
4. Policy Statements
Personally Identifiable Information
- PII is any information about an individual maintained by an agency, including (1) any information that can be used to distinguish or trace an individual‘s identity, such as name, unique identification number, date and place of birth, mother‘s maiden name, or biometric records; and (2) any other information that is linked or linkable to an individual, such as medical, educational, financial, and employment information.
- PII may be divided into two categories: linked information and linkable information. Linked information is any piece of personal information that can be used to identify an individual and includes, but is not limited to, the following:
- Full name
- Home address
- Email address
- Unique identification number
- Passport number
- Driver’s license number
- Credit card numbers
- Date of birth
- Telephone number
- Log in details
- Biometric information (Fingerprint)
Linkable information, on the other hand, is information that on its own may not be able to identify a person, but when combined with another piece of information could identify, trace, or locate a person.
Linkable information, on the other hand, is information that on its own may not be able to identify a person, but when combined with another piece of information could identify, trace, or locate a person.
Collection of Personal Data
- ValuEnable shall define and describe what is considered Personally Identifiable Information.
- ValuEnable shall collect the personal data of the ValuEnable customer/clients employees or any other entity only for its legitimate business purposes.
- ValuEnable may collect the personal data of employees, customers or third parties as per the relevant business operation policies and procedures and will limit its collection, use, storage, processing, transfer and disclosure of personal data to a minimum that ValuEnable requires to carry its business specific purposes.
- Any ValuEnable Policy, including but not limited to business operations policies, procedure, technical documents, system design documents, defining the collection of personal data at any level in ValuEnable shall adhere to the data privacy policy.
- Personal data or Personal Identifying Information (PII) may only be collected, used, stored, processed, transferred or disclosed for reasonable, specific and lawful purposes or reasons.
- Business departments shall be aware of the applicable data protection legislations or regulatory guidelines and comply with the same.
- Respective business departments shall implement adequate procedures regarding obtaining, identification of personal data or Personal Identifying Information (PII). This will include procedures to collect data from customers through the ValuEnable branch operations and employees (including third party employees and trainees).
- ValuEnable management shall be responsible to identify data which requires specific compliance requirements regarding protection and privacy.
- In case when data is collected directly from data subjects, ValuEnable shall ensure that the privacy notice is conspicuous and uses clear language
- ValuEnable shall communicate that they can contact the entity in case their PII needs any correction/ modification, through writing, by phone, by email, or by using the organisation's Website.
- ValuEnable should verify the accuracy and completeness of PII that an individual updates by means of a self-declaration form or supporting evidence provided at the time of making those changes
- To make our Platform and Services more useful to you, our servers (which may be hosted by a third-party service provider) collect information from you, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), and domain name.
- We may use third party service providers to help us analyze certain online activities. For example, these service providers may help us analyze visitor activity on the Platform. We may permit these service providers to use cookies and other technologies to perform these services for us.
- We use authorised third-party service providers to power payment transactions on our platform. Further, as per the applicable regulations, we use tokenisation services from certified third-party service providers to facilitate card transactions on our Platform. The third-party service providers use/process such information and further transfer your information to the card networks (such as Visa, Mastercard). Such third-party service providers have the necessary rights to use/process/transfer such information to provide tokenisation services in accordance with the applicable regulations. Such third-party service providers are PCI-DSS compliant. We do not store any information that is provided by you to facilitate such card transactions on our Platform.
4.1 Consent
- ValuEnable shall not collect, use or disclose any personal data without the consent of the data owner except where there is deemed consent or where such collection, use or disclosure is required to meet the requirements of country specific laws and regulations, if any.
- ValuEnable shall seek consent from a competent person before collecting, processing and disclosing PII concerning a child.
- "Cookies" are pieces of information that a browser can record after visiting a website. We may use cookies for technical purposes such as to enable better navigation through our site, or to store user preferences for interacting with the site. If you turn off the option to have cookies stored on your browser, it will affect your experience on https://loan.valuenable.in/
4.2 Notification
Individuals shall be notified of the purposes for which ValuEnable intends to collect, use or disclose personal data before or when such data is collected. In the event that any intended use of personal data will go beyond the purposes notified during collection, ValuEnable employees will notify the relevant individual of the new purpose and seek that individual’s consent to use the data for such a purpose.
4.3 Protection of personal data
4. Policy Statements
Personally Identifiable Information
Aadhaar Regulations
Includes the Aadhaar (Targeted Delivery of Financial and other subsidies, Benefits and Services) Act 2016, Aadhaar (Amendment) Act 2019, Aadhaar (Authentication) Regulations 2016, Aadhaar (Data Security) Regulations 2016, and other applicable regulations issued by UIDAI from time to time.
Consent
Freely given, specific, and informed indication of the data subject's wishes by which they signify agreement to the processing of their personal data.
Data Controller
The person responsible for complying with data privacy requirements who has full authority to decide how and why personal data is processed.
Data Subject
A natural person who is the subject of data.
Insurance Data
Data related to life insurance policies issued by various insurance companies, including data of customers who hold insurance policies.
Personal Data or Information
Information relating to a natural person capable of identifying such person, either directly or indirectly.
Sensitive Personal Data or Information
Includes information relating to passwords, financial details, health conditions, sexual orientation, biometric information, etc.
The User
The individual using our Service.
Cookies
Small pieces of information that a browser can record after visiting a website. We may use cookies for technical purposes such as enabling better navigation through our site or storing user preferences. Turning off cookies will affect your experience on https://loan.valuenable.in/.
- Board of Directors
- Respective Department Heads
- CISO
- Legal & Compliance Team
- All Employees
Purpose
The purpose of this Policy is to enable ValuEnable to:
- Implement reasonable security practices and procedures to safeguard personal data and sensitive personal data.
- Comply with applicable statutory provisions, rules, and regulations regarding data privacy and protection.
- Enable the data subject and third parties to understand and comply with ValuEnable's data privacy policies
Transfer / Disclosure of Data or Information
- Personal data, sensitive personal data, and other customer data will not be transferred or disclosed to any third party without implementing reasonable security practices and obtaining explicit consent from the data subject.
- Information may be communicated to third parties only for purposes consistent with the original collection purpose or as authorised by law.
- Disclosure of information to data subjects must be transparent, providing details about the purpose of collection, usage, and security practices.
- We may be required from time to time to disclose any personal information collected by us to governmental or judicial bodies, agencies, or our regulators based on legal requirements under applicable cyber laws. We may also share your information with third-party group companies to enable service provision and/or carry out technical, logistical, and other functions on our behalf (e.g. sending emails or newsletters to users). For credit facilitation services, please refer to Section 4 above.
Data Subject's Rights
Data subjects are entitled to:
Data Security
ValuEnable Pvt Ltd is committed to protecting the security and privacy of your personal information. We endeavour to have suitable technical, operational, and physical security controls and measures in place that are commensurate with the nature of our business.
Breach Notification
In the event of a data breach, ValuEnable will notify the affected data subjects and relevant authorities promptly, outlining the nature of the breach and the steps taken to mitigate its impact.
Data Minimization
We will collect only the data necessary for the specified purposes and ensure it is used solely for those purposes.
Data Retention & Deletion
It may be noted that we may retain your data for as long as required under applicable law and as necessary to efficiently provide our services. All information provided by you, except in cases of withdrawal of consent or termination, shall be retained for a duration of eight (8) years. We will act upon any deletion request received from you within a reasonable period, and in any case, no later than thirty (30) days from receipt of such a request.
We may retain certain data after account deletion for specific purposes, including but not limited to:
- If there is an unresolved issue, claim, or dispute relating to your account.
- Where retention is required under applicable law.
- In aggregated and/or anonymized form.
- Where necessary for legitimate business interests, such as fraud prevention, enhancing user safety, and ensuring security.
Data Destruction Practices
We apply industry-standard sanitization practices (aligned with authoritative media-sanitization guidelines) and maintain documentation of our processes for compliance and audit readiness. Structured data (such as SQL table rows) is securely erased at the record level using irreversible methods. Any residual data in logs or replicated storage is minimized and retained only for the period required under law or internal policy.
Amendments to Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Third-Party Service Providers
Below is the list of third-party service providers with which the Company shares customer data in order to provide the Service(s).
For Axis Finance related grievance:
For more details, please visit:https://www.axisfinance.in
For Axis T&C, please visit:https://www.axisfinance.in/policies-and-standards/terms-conditions
Contact details of grievance redressal officers of BFL - https://www.bajajfinserv.in/grievance-redressal
Geojit Credits Pvt. Ltd.:
For any grievance, the first point of contact will be the Grievance Redressal Officer of Geojit Credits Private Limited at-grievances@geojitcredits.com
RBI's Sachet Portal link -https://sachet.rbi.org.in/
RBI’s Complaint Management System (CMS) link -https://cms.rbi.org.in/cms/indexpage.html#eng
