RBSG Capital Private Limited (‘the Company’) is a Non-Banking Financial Company (‘NBFC’) having valid Certificate of Registration with Reserve Bank of India (‘RBI’) vide registration no. N-13.02241 dated May 17, 2018 under current RBI classification as NBFC-ND-NSI (Non-Banking Finance Company- Non-Deposit taking-Non-Systematically Important) It is focused on offering financing of all kind of commercial vehicles (HCV, LCV, MUV, SCV) and Cars.
Technology (Intermediaries Guidelines) Rules, 2011. At RBSG Capital Private Limited (hereinafter referred to as “the Company”), privacy issues are of
❖ WHAT INFORMATION DO WE COLLECT ?
We may collect and process the following data about you:-
- Information you give us about you (Submitted information).
- Provided by filling informs in the Platform.
- Provided by corresponding with us (for example, bye-mail or chat).
- Including information, you provide when you register to use the Platform, subscribe to any of our services (such as applying for a loan from the Company), search for a service, share data via the Platform, enter a competition (if any), promotion or survey, and when you report a problem with the Platform, our services, or any of our sites and/or mobile application.
- Information we collect about you and your device. Each time you visit one of our Sites or use one of our Apps we may collect the following information;
- Information to red on your device (Content Information);
- Details of your use of any of our mobile applications or your visits to any of our sites including, but not limited to, traffic data, location data, web logs and other communication data (Log Information).
- Location information: We may also use GPS technology or other location services to determine your current location.
- Information we receive from other sources (Third Party Information). We reserve the right to work with a limited number of third parties (including credit reference agencies, mobile network providers, and collection agencies, etc.) and may receive information about you from them.
❖ COLLECTION OF PERSONAL INFORMATION
We will only use the information we collect about you lawfully and in accordance with the Information Technology Act, 2000, the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 and other applicable laws of India. We may collect your personally identifiable information such as name, postal address, email address and phone number, the device’s phone number, SIM card, age, username, password and other registration information, financial and credit information, personal description, photograph names, credit or debit card information
and other payment instrument details etc. which you voluntarily provide to us for facilitating the services provided by the Company. Depending on the activity, some of the information we ask you to provide is identified as mandatory and some is identified as voluntary.
If you do not provide the mandatory information for a particular activity, you will not be permitted to engage in that activity. You are not required to provide the personal information that we have requested, but, if you chose not to do so, in many cases we may not be able to provide you with our services or respond to any queries you may have.
offerings. For example, if you send our customer service an email we may use your comments and feedback to tell others about our services, and may post your comment in our marketing materials or on our Platform. In addition, if you use our Platform to send information to another person, we may store
your personal information, and the personal information of any recipient and we may use that other person’s contact information to allow him or her to access/view such information. We may also use personally identifiable information to troubleshoot, resolve disputes, accomplish administrative tasks,
We also collect from our users non-personally identifiable information. This information does not identify a specific user. We, and/or our authorized third party service providers and advertisers, may automatically collect this information when you visit our Platform through the use of electronic tools like cookies and web beacons or pixel tags. We use non personally identifiable information to trouble shoot, administer the Platform, analyze trends,
gather demographic information, comply with applicable law, and cooperate with law enforcement activities. We may also share this information with our authorized third party service providers and advertisers to measure the overall effectiveness of our online advertising, content, and programming.
❖ IS MY PERSONAL DATA STORED SECURELY?
We use best security systems and practices designed to protect your information and to prevent Unauthorized access to your data. Examples of our security practices include:
- Sensitive user data, such as account passwords and email addresses, are stored in encrypted format.
- Automatic applications and infrastructure are regularly tested for security vulnerabilities and hardened to enhance security and protect against attacks.
- User data on our data base is logically segregated by account-based access rules. User accounts have unique user names and passwords that must be entered each time a user logs on.
- We are committed to handling your personal information with respect and care. However, regardless of the security precautions taken, no physical, Internet or other electronic transmission or storage of data can be fully secure or error free. We recommend that you do not share your password with anyone. You should understand this when choosing to use any product or services that include the physical or electronic storage or transmission of your data.
❖ RELEASE OF YOUR INFORMATION
- We may share your personally identifiable information with other parties in case of the following:
- We may share your information with other parties who provide products or services through us.
- We may share your personally identifiable information with them so that they can contact you regarding a transaction. However, we will only share personally identifiable information if you engage in an identification activity, and then only to those involved in that identification activity. Notwithstanding the
above, the Company will only do so with opt-in notice to you, in which you will have a chance to choose that the Company not give them your personal information.
❖ OTHER DISCLOSURE
We may disclose some or all of the data we collect from you when you use the Platform to Credit Information Company/ies (‘CIC’) and external collection agencies.
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets;
- If the Company or substantially all of its assets are acquired by a third party, in which case personal data held by it about its users/customers will be one of the transferred assets;
- If you authorize said disclosure;
- Engage a third party collections agency; or
- For the purpose of publishing statistics relating to the use of the Platform, in which case all information will be aggregated and made anonymous.
❖ RELEASE OF NON-PERSONALLY IDENTIFIABLE INFORMATION
- We may use your data for the purposes of compiling statistics relating to our user base or loan portfolio and may disclose such information to any third party for such purposes, provided that such information is used anonymously.
- We may disclose or share non-personally identifiable information with partners, affiliates and advertisers.
- For example, we may share aggregated demographic information (which does not include any personally identifiable information) with “third party advertisers” or “third party advertising companies”.
- We may use third party advertising companies to serve ads when you use our Platform. These companies may use non-personally identifiable information about your visits to this and other websites inorder to provide, through the use of network tags, advertisements about goods and services that may be of interest to you.
- We may also use third party service providers to track and analyze non-personally identifiable us age and volume statistic al information from our users to administer our Platform and constantly improve its quality.
- We may also publish this information for promotional purposes or as are presentative audience for advertisers. Please note that this is not personally identifiable information, only general summaries of the activities of our users.
❖ DATA TRACKING
Session Data: We may automatically log generic information about your computer’s connection to theInternet, which we call” session data”, that is anonymous and not linked to any personal information. Session data consists of information such as the IP address, operating system, type of browser software being used by you and the activities conducted by you on our Platform. An IP address is a number that lets computers attached to the Internet, such as our web servers, know where to send data back to the user, such as the pages of the site the user wishes to view. We collect session data because it helps us analyze things such as the items visitors are likely to click on most, the manner in which visitors click preferences on our Website, number of visitors surfing to various pages on the site, time spent by the visitors on our Web site and frequency of their visit. It also helps us diagnose problems with our servers and lets us better administer our systems. Although such information does not identify any visitor personally, it is possible to determine from an IP address a visitor’s Internet Service Provider (ISP), and the approximate geographic location of his or her point of connectivity.
Other Tracking Devices: We may use other industry standard technologies like pixel tags and web beacons to track your use of our Platform pages and promotions, or we may allow our third party Service providers to use these devices on our behalf. Pixel tags and web beacons are tiny graphic images placed on certain pages on our Platform, or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, pixel tags and web beacons generate anon-personally identifiable notice of that action. Pixel tags allow us to measure and improveour understanding of visitor traffic and behavior on our Platform, as well as give us away to measure our promotions and performance. We may also utilize pixel tags and web beacons provided by our affiliates and/or marketing partners for the same purposes.
❖ PRIVACY POLICIES OF THIRD PARTY PLATFORMS
- Our App uses background Location permission for ensuring you are based in India and for the purpose of
- on-boarding/ know-your-customer (KYC) requirements
- Our App uses Camera permission for taking pictures.
- Our App uses Contacts permission for getting contact information
- Our App uses Phone state permission for getting phone state information
- Our App uses Get Accounts permission for getting accounts from devices.
- Our App uses Call logs permission for verification purposes.
- Our App uses SMS read permission to access your SMS. we read your SMS to autofill and verify the OTP used to validate your mobile number when creating an account with AutoMony – this provides you a seamless experience during that process. We also collect your SMS data to analyze the data around specific financial transactions for statistical analysis or for credit rating.
❖ MISCELLANEOUS PRIVACY ISSUES
Public Areas: We may provide are as on our Platform where you can publicly post comments and information about yourself or can review products and submit media content. This information may be accessible by other consumers and companies and may appear on other websites or web searches, and therefore this information could be read, collected, and used by others. For example, if you post your email address along with a public review, you may receive unsolicited messages. We have no control over who reads your postings or what other users may do with the information you voluntarily post, so please use caution when posting any personal information.
The Company’s MD, CFO and COO have been entrusted with the responsibility of enforcement of this policy. They are hereby given absolute power to jointly or severely, make necessary changes, amendments or additions or removals for the operational aspects of the policy within the overall spirit and guidance from time to time for reasons like technology or process up gradation, regulatory changes, maintaining competitive edge or responding to changes in market or risk environment, etc. This is required to ensure full operational freedom to the senior management and make the management team more adaptive to rapid changing external environment. All changes so made shall be noted to the policy approving authority during the next policy review.
The MD, CFO and COO can decide on delegation of authority and can design/redesign MIS systems and reporting as they see fit to improve the responsibility and accountability within the team hierarchy.