Updated as on 01.10.2022

PART – A

Prodigee Finance Limited [company] is committed to protect user’s privacy, maintaining secrecy and confidentiality of information/Data of customers/borrowers and working towards offering Users a safe and secured online experience. The Privacy Policy governs the use of this website https://prodigeefinance.com (Website) of Prodigee Finance Limited and Prodigee Finance values of the privacy of the Users.

The privacy policy of Prodigee Finance Limited covers collection, uses and sharing of data/ information given by the user/customer while visiting the company’s website. The policy describes what information we collect from customer, how we collect these information and what we do with it after we collect it. By using our website, customer gives consent to use their personal information by company in accordance with the terms set out in this Privacy Policy. We may make changes to the Privacy policy from time to time at our own or as per RBI directives. We will notify of any material changes to the privacy policy by way of a notification on our website or displaying a revised policy on our website. This policy is made within the framework of RBI guidelines contained in RBI circular no. RBI 22-23/111 Dated 2/9/2022.

COLLECTION, USES AND SHARING OF INFORMATION/DATA WITH THE THIRD PARTIES 

1] Personal Information – We collect need based personal information of the Customers/borrowers  which includes but is not limited to name, mailing address, phone number, PAN number, Aadhaar number (masked data), bank account number, passport details, ITR, bank statements, purpose of loan and other financial information. We may ask the customers/borrowers to provide additional information about the customers, if required for the purpose of rendering our services. The above information is collected with prior and explicit consent of the customer/borrower. We do not access mobile phone resources like file, and media, contact list, call logs, telephony functions etc. However we may take a one-time access to the camera, microphone, location, or any other facility necessary for the purpose of on-boarding/ KYC requirement only, with the explicit consent of the customers/Borrower. We may capture the economic profile (age, occupation, income etc.) of borrower and assess the borrower’s creditworthiness in an auditable way before extending any loans directly at our level and/or over DLAs.

2] Option to Customers/Borrowers – The borrowers shall be provided with an option to give or 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.

3] Uses – We use the information to understand your credit profile and provide you with a better service. We also might send you promotional emails about new products, special offers or any other information which might be of relevance to you with your explicit consent. The purpose of obtaining borrower’s consent should be disclosed at each of interface with the borrowers

4] Sharing of Information – Explicit consent of the borrowers is taken before sharing personal information with any third party, except for cases where such sharing is required as per statutory or regulatory requirement such as sharing of information with the CICs, court of law, law enforcing authorities, RBI and  Bankers. All new digital lending products extended by us over merchant platforms involving short term credit or deferred payments shall also to be reported to CICs as per RBI guidelines.

We will not sell or distribute the information to third parties unless we have explicit permission to do so from the borrowers. If any information that the borrowers have provided to us is either incomplete or incorrect, they may write to us at our email [email protected].

We never publicly disclose any personal information related to financial or payment activities or any government identification numbers.

By signifying,  the borrower give  acceptance to the provisions of this  Privacy Policy and by providing  personal information, the borrower  consent to the  use of such personal information in accordance with this Privacy Policy, including but not limited to consent for sharing personal information as per this Privacy Policy. The borrower should specifically agree and consent to the company for collecting, storing, processing, transferring, and sharing information (including personal information) in the manner set out in this Privacy Policy.

All information, including personal information, disclosed by the borrowers shall be deemed to be disclosed willingly and without any coercion. No liability pertaining to the authenticity/ genuineness/ misrepresentation/ fraud/ negligence, etc. of the information disclosed shall lie on the company nor will the company in any way be responsible to verify any information obtained from the borrower.

 

STORAGE OF INFORMATION/DATA

1] We shall not store personal information of borrowers except some basic minimal data [Viz., Name, address, contact details of the customers, KYC, etc.] that may be required to carry out their operations. All other information/data will be deleted 48 hours post disbursement of loan applications.

2] Data/information shall be used internally to comply with the RBI regulations such as KYC norms and economic profile of borrower and to assess the borrower’s creditworthiness in an auditable way – We may capture the economic profile of the borrowers (age, occupation, income etc.) before extending any loans at our level and/or over DLAs, with a view to assess the borrower’s creditworthiness in an auditable way.

3] Data destruction shall be done under the supervision of Head of the concerned department and Managing Director of the company.

4] In case of security breach, the proper inquiry shall be done and suitable action to be taken against erring officials. In case of any fraud is detected, the same shall reported to concerned authorities including POLICE/CBI/EOW and FIU etc.

5] No biometric data is either stored or collected in the system, unless allowed under extant statutory guidelines.

6] All data is stored in the server located in India duly complying statutory obligations/regulatory instructions.

 

COOKIES USAGE

A cookie is a small file placed on the hard drive of computer. We use cookies to track use of the website and provide a more personalized user experience. The user may choose either to accept or decline cookies. Most web-browsers automatically accept cookies, but the user can change the browser settings to decline cookies as well.

 

DATA MINIMISATION

The company shall ensure that personal data are adequate, relevant, and limited to what is necessary in relation to the purposes for which they are possessed.

 

ARCHIVING/REMOVAL

To ensure that personal data is kept for no longer than necessary, all the information will be deleted/removed as per the Point No. 1 above. The user can also reach the company to delete his account and information/data by mail subject to closure of all the ongoing services.

DUE DILIGENCE & SECURITY

Data security is our priority. To prevent unauthorised access, we have the required procedures and firewalls (both electronic and physical) to safeguard the data.

STEPS FOR HANDLING SECURITY BREACH

1. Move quickly to secure the systems and fix vulnerabilities that may have caused the breach.
2. Switch off the servers and change the access code to prevent additional data loss.
3. Mobilize the breach response team right away to prevent additional data loss.
4. We are duly complied with technological standard on cyber security stipulated by RBI and other agency or as may be specified from time to time for undertaking digital lending. Moreover if additional security will be required, the same will be appropriately placed.
5. Securely delete personally identifiable information (PII) and other sensitive data when it no longer needed for business purposes.

OTHER SITES LINKS

We provide links to other websites within our site. Once the customer uses these links to leave our website, we cannot guarantee the privacy of any data that may have divulged on these websites. The customer should exercise caution and read the privacy policy of the concerned website before sharing any data.

COMMUNICATIONS

WhatsApp option – ‘By Signing Up, the user agrees to receive communication from the company via WhatsApp, Email, Messaging or any other communication channel.

CHANGES IN PRIVACY POLICY

Our Privacy Policy might change from time to time, and the company will provide notice of it email address linked to borrower’s Account or can be seen on our website.

COMPREHENSIVE PRIVACY POLICY

We ensure that Digital lending Apps/Platform or Lending service provide [LSP] make their comprehensive privacy policy compliant with applicable laws, associated regulations, and RBI guidelines. The details of third parties [wherever applicable] allowed to collect personal information through the DLA/LSP shall also disclose in their privacy policy.

Being the regulatory entities we ensure that our DLA/platform and/or DLA/platform of LSP are implementing Privacy policy in letter and spirit.  

CONTACT US

If the borrowers have questions, concerns, or grievances regarding this Privacy Policy, they can email to our grievance officer: The Grievance Officer can be contacted between 09:30 a.m. to 6:00 p.m. from Monday to Friday except on public holidays.

 

Officer Name: Mr. Rohit Bunkar

Officer Email: [email protected]

 

PART – B

USAGE OF WEBSITE: Terms and Conditions

Prodigee Finance Limited treats Users personal information or Users use of service as private and confidential and does not reveal it to any third parties except where it believes in good faith, such action is necessary to comply with the applicable legal and regulatory processes or to protect and defend the rights of other Users or to enforce the terms of service which are binding on all the Users of https://prodigeefinance.com

Our website https://prodigeefinance.com does not collect personal information about individuals except when such individuals specifically provide such information on a voluntary basis which information will not be sold or otherwise transferred to any unaffiliated third parties unless otherwise stated at the time of collection or with the approval of the Users as the case may be  Private & Confidential.

Prodigee Finance Limited will not send Users any unsolicited information except where specifically agreed or necessary for operational or regulatory reasons. Prodigee Finance Limited reserves the right to use mobile numbers of Users to send occasional SMS pertaining to information on product and services.

All information submitted to Prodigee Finance Limited via this site shall be deemed and remain the property of Prodigee Finance Limited and Prodigee Finance Limited shall be free to use, for any purpose, any idea, concepts, know-how or techniques contained in information given by any Users to this site provides Prodigee Finance Limited through this site. However, Prodigee Finance Limited shall not be subject to any obligations of confidentiality regarding submitted information except as agreed by Prodigee Finance Limited having direct customer relationship or as otherwise specifically agreed or required by law.

Users, who believe they are receiving our communications in error or no longer desire to receive them, should inform us and we will remove those Users’ names from our mailing lists. Prodigee Finance Limited reserves its right to correct any part of the content of the Website at any time as and when required at its sole discretion.

CONTENT PRIVACY

Intellectual Property: We grant Users the right to access this Web Site in accordance with these terms and conditions, and for no other purpose. Please note that the services and content on the Web Site, including but not limited to text, content, photographs, video, audio and graphics, are either the property of, or used with permission by, Prodigee Finance Limited and may be protected by applicable copyrights, trademarks, service marks, international treaties and/or other proprietary rights and laws of India and other countries. The trademarks, logos, slogans and service marks (collectively the “Trademarks”) displayed on the Web Site, are registered and unregistered Trademarks of Prodigee Finance Limited and others. Nothing contained on the Web Site should be construed as granting, by implication, estoppel, or otherwise, any license or right to use any Trademark displayed on the Web Site without the written permission of Prodigee Finance Limited or such third party that may own the Trademarks displayed on the Web Site. Users’ misuse of the Trademarks displayed on the Web Site, or any other content on the Web Site, except as provided in these Terms and Conditions, is strictly prohibited. Users are also advised that Prodigee Finance will aggressively enforce its intellectual property rights to the fullest extent of the law, including the seeking of criminal prosecution. We shall be entitled to obtain equitable relief (including all damage, direct, indirect, consequential and exemplary), over and above all other remedies available to us, to protect our interests therein.

Restrictions on use: Users agrees to use the Web Site strictly for Users personal use. Users agree not to use this Web Site for any illegal purpose or in any manner inconsistent with these Terms and Conditions. Users agrees not to use, transfer, distribute or dispose of any information contained in the Web Site in any manner that could compete with the business of Prodigee Finance Limited or otherwise compromise or imperil the interests of Prodigee Finance Limited. Users acknowledges that the Web Site has been developed, compiled, prepared, revised, selected and arranged by Prodigee Finance Limited and others (including certain other information sources) through the application of methods and standards of judgment developed and applied through the expenditure of substantial time, effort and money and constitutes valuable Private & Confidential intellectual property and may also include trade secrets of Prodigee Finance Limited and such others. Users agree to protect the proprietary rights of Prodigee Finance Limited and all others having rights in the Web Site or its content during and after the term of this agreement and to comply with all reasonable written requests made by Prodigee Finance Limited or its suppliers of content, equipment or otherwise to protect their and others contractual, statutory and common law rights in the Web Site. Users agree to notify Prodigee Finance Limited in writing promptly upon becoming aware of any unauthorized access or use of the Web Site by any party or of any claim that the Web Site infringes upon any copyright, trademark or other contractual, statutory or common law rights. Users may download and retrieve data from the Web Site on Users computer screen, print individual pages on paper, photocopy and store such pages in an electronic form on disk (but not on any server or other storage device connected to a network) for User exclusive personal use only. Users further acknowledge that all the intellectual property in the Web Site continues to vest with us.

Privacy Restrictions: The content of this Website shall not be displayed or printed in any form in part or whole without the prior written approval of Prodigee Finance Limited. The information contents provided on this Site or the company logo cannot be copied, modified, uploaded, downloaded, published or republished, transmitted or otherwise distributed for commercial purposes without prior and explicit permission from Prodigee Finance Limited. Reproduction of any information or material provided on this Website, with or without any modification, is prohibited unless, with prior permission of Prodigee Finance Limited, and shall amount to violation of copyright and would be deemed an illegal act.

Access Restrictions: We reserve the right to deny to Users, at our sole discretion, access to the Web Site, including any portion thereof, without any prior notice. Use of the Website, https://prodigeefinance.com is available only to persons who can form legally binding contracts under applicable law. Persons who are “incompetent to contract” within the meaning of the Indian Contract Act, 1872 including un-discharged insolvents, etc. are not eligible to use the Website.

 

Approved by the Board of Directors vide Resolution dated 1^st October, 2022

Amit Goel

DIN: 06373510

Managing Director

Date: 01.10.2022

Place: Bhopal