Aspire Finance Private Limited (“our”, “us”, “we”, “Company”, “Aspire”), has received in-principle approval for a base layer non-deposit taking Non-Banking Financial Company from the Reserve Bank of India. Aspire operates the website www.aspirefinance.in (referred to as the “Platform”) and is committed to protecting Your privacy and the information that You share while using the Platform. We value the trust You place in Us. That’s why, We maintain the highest security standards for securing the transactions and Your information.

By visiting and clicking on the “I agree” button provided on the Platform You (“you”, “your”, “user”, as applicable) accept and agree to be bound by the terms and conditions of this privacy policy (“Privacy Policy”). We may also seek your explicit consent on the Platform for certain requirements such as for sharing your data with third parties among other things as may be communicated to you in writing on the Platform.

This Privacy Policy (i) is an electronic record under the Information Technology Act, 2000 read with rules and regulations made thereunder or such other law for the time being in force and is generated by a computer system; and (ii) does not require any physical, electronic, or digital signature. This Privacy Policy is incorporated into and subject to the Terms of Use of the Platform (“Terms”) and shall be read harmoniously and in conjunction with the Terms. All capitalized terms used and not defined in this Privacy Policy shall have the meaning ascribed to them under the Terms.

This Privacy Policy describes the information we collect, how that information may be used, with whom it may be shared, and your choices about such uses and disclosures. You must read this Privacy Policy carefully when using or transacting over the Platform. If you do not agree to this Policy or any part thereof, please do not use or access our Platform or any part thereof.

This Privacy Policy does not apply to information that You provide to, or that is collected by, any third-party through the Platform, and any Third-Party Sites that You access or use in connection with the Services offered on the Platform.

In order to provide you the Services, process your loan requests, and to provide a loan to you, we need to collect various data and information from you. The manner in which this data and information is collected, retained, shared, stored, and processed Us is addressed in this Privacy Policy.

1. Privacy Related Questions?

We have appointed a data grievance officer. Our data grievance officer is Manoj Kumar Rathi, accessible via email at compliance@aspirefinance.in. You can contact the grievance officer by email, If You have any grievance with respect to the Platform or the Services.

2. What Data We Collect and Why?

By using the Platform, you consent to providing us data in the ways listed below. We collect the data you provide to ensure that we can provide you Services in the best manner possible.

Ways of collecting data:

1. Data you entered during registration on the Platform.
2. Data we collect from your usage of our Services.
3. Information we receive from other sources.

COLLECTION OF PERSONALLY IDENTIFIABLE INFORMATION

In general, you can browse the Platform without telling us who you are or revealing any Personal Information about yourself. However, to create an account on the Platform and to avail our Services, you must provide us with certain basic information required for us to verify your identity under our robust KYC process, to assess your creditworthiness, and to provide you customized services among other things. When you use our Platform, we may, with your consent and from time to time, collect and store your personal information)

The personally identifiable information we collect from you includes the following:

1. Your full name;
2. Date of birth;
3. Email;
4. Address;
5. Phone number;
6. Permanent Account Number (PAN);
7. Aadhaar Number for KYC process;
8. Gender;
9. Bank account details for NACH setup and disbursal

The above information is collectively referred to as (“Personal Information”).

We may ask you to provide certain additional information about yourself on a case-to-case basis. All information provided by you shall be deemed to be disclosed willingly and without any coercion. No liability pertaining to the authenticity / genuineness / misrepresentation / fraud / negligence of the information disclosed shall lie on the Company nor will the Company be in any way responsible to verify any information obtained from you.

Our primary goal in collecting your Personal Information is to provide you a safe, efficient, smooth, and customized experience on the Platform and to provide our 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.

We may also collect your mobile number for verification purposes to check the active SIM status on the device, uniquely identify you and prevent frauds and unauthorised access. We may also collect other Personal Information such as your payment card details and transaction histories on the Platform among other things.

Where possible, we indicate the mandatory and the optional fields. 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 us on the Platform) requires registration and for you to provide the aforementioned Personal Information. The Platform shall 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.

We may retrieve your Personal Information from your records available with third parties including from the Central KYC Records Registry (CKYCR) and Know Your Customer (KYC) Registration Agencies (KRA). The Personal Information collected therein may include Your name, KYC details, KYC status, father’s/spouse’s name, occupation, address details and other related documents for completion of your KYC which is required for us to provide you loans/credit products through our Platform.

COLLECTION OF FINANCIAL INFORMATION

We ask you for certain financial information, including your bank account details and type, Indian financial system code (IFSC) of bank, and/or other necessary payment related details. We may also require You to provide additional information such as proof of address, residence ownership type, location, annual income, employment type, and source of income, number of years in employment, employer name, employer address, designation, official email address, business name, business address, nature of business, and additional income source, and Aadhaar data to facilitate in evaluation of Your credit profile and creditworthiness.

We don’t collect or store your personal SMS or messages from your inbox, nor do we collect your files, contact list or call logs.

 COLLECTION OF MOBILE NUMBER AND EMAIL ADDRESS

When you sign up with us, we collect your mobile number and email address to uniquely identify you. This helps us ensure that no unauthorised device or person is acting on your behalf.

COLLECTION OF LOCATION INFORMATION

We seek explicit permissions from you to receive information about your location, your IP address and such other information as may be required for onboarding you on the Platform (through a one-time permission to access and process such information at the time of onboarding and KYC collection). In addition to the above, your location data also helps us to verify the address, make a better credit risk decision and expedite your KYC process.

CAMERA

We require a one-time access to your camera to provide you an easy/smooth experience and to enable you to click photos of your KYC documents along with other requisite documents and upload the same on the Platform during your loan application journey.

COLLECTION OF OTHER NON-PERSONAL INFORMATION

We may 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.

Cookies are small data files that a website stores on Your computer. We will use cookies on our Platform similar to other lending websites / apps and online marketplace websites / apps. Use of this information helps Us identify You in order to make our Platform 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 Platform.

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 access, store and use the information we collect from you including your Personal Information to provide our Services, to customize your user experience and to improve our Services. To the extent we intent to use your Personal Information to market any of our product to you, we will provide you the ability to opt-out of such uses.

We also use your Personal Information to:

1. resolve disputes;
2. troubleshoot problems;
3. help promote a safe service;
4. analytical analysis;
5. measure consumer interest and satisfaction in our products and services;
6. inform you about online and offline offers, products, services, and updates;
7. customize your experience;
8. detect and protect us against suspicious or illegal activity, fraud and other criminal activity;
9. enforce our Terms;
10. improvement of our Services and as otherwise described to you at the time of collection;
11. to help promote a safe service on the Platform and protect the security and integrity of the Platform, the Services, and the users;
12. to contact you;
13. for any other purpose after obtaining your consent at the time of collection.

In our efforts to continually improve our product and service offerings, we collect and analyse demographic and profile data about our users’ activity on our Platform.

We will use Your information for such periods as necessary to provide You the Services on our Platform, to comply with our legal obligations, to resolve disputes, and enforce our agreements.

DISCLOSURE TO THIRD PARTIES

We will share Your information only with our registered third parties service providers who have partnered with us and with whom we have a contract (in line with all applicable data protection laws in India and RBI guidelines, directions, notifications, and circulars). Your information so disclosed shall be used only for the provision of Services on the Platform and/or for facilitation of a loan / facility to you. The list of third parties with whom we share your information is available here. We will share Your information with third parties only in such manner as described below:

1. We disclose and share Your information with third party partners for facilitation of a loan or facility or line of credit through the Platform;
2. We share Your information with our third-party partners in order to conduct data analysis in order to serve You better and provide Services on our Website;
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 interacts with the Platform.
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 then any business entity (or the new combined entity) receiving any such information from Us shall be bound by this Privacy Policy with respect to your information.
6. We will disclose the information to 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 consenting to this Pricay Policy or by providing your consent when sought on the Platform , you hereby grant your explicit, free, specific, informed, unconditional and unambiguous 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 India.

In case we use or disclose your information for any purpose not specified above, we will take your explicit consent on the Platform.

CHANGES IN THIS PRIVACY POLICY

The Company reserves 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 Website. 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. You can determine if changes have been made by checking the “Last Updated” legend above.

ACCESSING YOUR INFORMATION / CONTACTING US

At any point of time Users can choose to edit/modify or delete any Personal Information shared for use of the Platform. Please note that deleting 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. Delete your entire account.
2. You can also request to remove content from our servers based on applicable law or by writing to our Grievance Officer.

SECURITY PRECAUTIONS

The Company intends to protect your Personal Information and to maintain its accuracy as confirmed by you. We implement reasonable physical, administrative and technical safeguards to help us protect your Personal Information from unauthorized access, use and disclosure. For example, we encrypt all sensitive Personal Information when we transmit such information 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 India as per the 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.

We work hard to protect from unauthorized access, alteration, disclosure or destruction of information we hold, including:

1. We use encryption to keep your data private while in transit;
2. We offer security feature like an OTP verification to help you protect your account;
3. We review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems;
4. 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.
5. Compliance & cooperation with regulations and applicable laws;
6. We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it.

DATA STORAGE AND TRANSFERS

All financial information gathered by us shall be stored on servers, log files and any other storage system owned by us or by third parties in India, and such storage will be need-based and to the extent required to render Services.

We or our affiliates maintain your information on servers located in India. We also comply with certain legal frameworks relating to the transfer of data as mentioned and required under the Information Technology Act, 2000 and the Digital Personal Data Protection Act, 2023 or such other applicable date protection/privacy law applicable at the time.

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 personally identifiable 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 Platform, 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 accepting this Privacy Policy and/ or by providing your consent on the Platform you hereby provide your explicit, free, specific, informed, unconditional and unambiguous consent to the collection and use of the information you disclose on the Platform in accordance with this Privacy Policy, including but not limited to Your consent for collecting, using, sharing and disclosing your information as per this Privacy Policy.

If we decide to change our Privacy Policy, we will post those changes on this page so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it.

You may choose to withdraw your consent (including regarding processing of data by Us or by any third party or regarding data retention) provided hereunder at any point in time. Such withdrawal of the consent must be sent in writing to compliance@letsaspire.in. In case you do not provide your consent or later withdraw your consent, we request You not to access the Platform and use the Services and also reserve the right to not provide You any Services on the Platform. In such a scenario, the Company may delete your information (personal or otherwise) or de-identify it so that it is anonymous and not attributable to You.

The Company allows for the erasure of your Personal Information. This is also known as ‘the right to be forgotten’ and, in simple terms, enables You to request the deletion or removal of your Personal Information where there’s no compelling reason for Us to keep it. Such right of erasure can be exercised by writing to Us at compliance@letsaspire.in.

Children’s Policy

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 account.

Managing Your information and Correcting inaccuracies in the information 

You may correct or update any information, including Your Personal Information online. You also have a right to (a) ask us for a summary of Personal Information being processed by Us and the processing activities undertaken by us with respect to such Personal Information; (b) the identities of all other third-party entities with whom the Your Personal Information has been shared by us, along with a description of the Personal Information so shared, except when such sharing is pursuant to a written request by such entity who obtains the information for the purpose of prevention or detection or investigation of offences or cyber incidents, or for prosecution or punishment of offences. You have the right to ask us to correct inaccurate or incomplete or misleading Personal Information concerning You or update Your Personal Information (which You cannot update yourself online) by contacting help@aspirefinance.in .

Right to Erasure

This is also known as ‘the right to be forgotten’ and, in simple terms, enables You to request the deletion or removal of Your Personal Information where there’s no compelling reason for Us to keep it. Such right of erasure can be exercised by writing to Us at help@aspirefinance.in . On such a request for erasure, we shall delete all Your Personal Information stored by Us, as well as ensure that any third-party service provider processing Your Personal Information on behalf of us deletes all Your Personal Information. This is not a general right to erasure; there are exceptions, such as when the law requires Us to retain certain personal information about You or where such retention is required for providing Our services to You, etc.

Right to Nominate 

You shall have the right to nominate, in a manner prescribed by the Central Government, any other individual, who shall, in the event of Your death or incapacity, exercise Your rights in accordance with applicable law in India.

Use of a Consent Manager  

You are permitted to give, manage, review, or withdraw Your consent provided to the Company to process Your Personal Information through a ‘consent manager’. A consent manager is an entity that is registered with the Data Protection Board. The consent manager is accountable to You and can assist You in providing or withdrawing Your consent to Us to process Your Personal Information, on Your behalf. Such consent managers must comply with the obligations imposed on them as may be prescribed by the Central Government.

Data Retention

We shall retain the information you provide to facilitate your smooth and uninterrupted use of the Platform , and (i) to provide, improve and personalize our Services; (ii) to contact you about your account and give customer service; (iii) to personalize our advertising and marketing communications;  (iv) to prevent, detect, mitigate, and investigate fraudulent or illegal activities; and (v) to comply with applicable laws. We shall be entitled to retain Your Personal Information and other information for such duration as may be required for the purposes specified hereunder or for such other periods as may be required under the applicable laws and the said information will be used by Us only in accordance with this Privacy Policy Notwithstanding anything contained herein, We will not retain your Personal Information and other information for longer than the periods provided below.

When the retention period for your Personal Information, KYC-related information, information generated through one-time access to camera and microphone as outlined above expires, We will actively destroy/delete such Personal Information and other information from Our systems. We will comply with the following procedure for destruction and disposal of your Personal Information and other information:

• Our IT department is responsible for deleting or destroying electronic records. This includes ensuring that the Personal Information and other information is permanently removed from company system and destroyed.

• No Personal Information and other information that are currently involved in, or have open investigations, audits, or litigation pending shall be destroyed or otherwise discarded.

• When retention requirements have been met, Personal Information and other information shall be immediately destroyed.

• The authorized methods of destruction for non-electronic Personal Information and other information are shredding.

We may, however, continue to retain Your Personal Information in anonymized form for analytical and research purposes.

 Exclusion

This Privacy Policy does not apply to any information other than information collected by us through the Platform including such information collected in accordance with the clause on “Collection of Information” above. This Privacy Policy will not apply to any unsolicited information provided by you through this Platform or through any other means. This includes, but is not limited to, information posted on any public areas of the Platform. All such unsolicited information shall be deemed to be non-confidential, and we will be free to use, disclose such unsolicited information without limitation.

Access to your Personal Information is limited to employees, agents, or partners and third parties, who we reasonably believe will need that information to enable us to provide Services to you. However, we are not responsible for the confidentiality, security, or distribution of your own Personal Information by our partners and third parties outside the scope of our agreement with such partners and third parties.

Communication From Us

We may from time to time send you Service-related announcements when we consider it necessary to do so (such as when we temporarily suspend the Platform for maintenance, or security, privacy, or administrative-related communications). We send these to you via SMS/push notifications/email/instant messaging, as we deem fit.

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:

Name: Manoj Kumar Rathi
Address: 1424, 2nd Floor, Behind Yelahanka, Old Town Post Office Nehru Nagar, Yelahanka, Bangalore, Karnataka, India.
Phone: +91 6362 098 268
Email: compliance@letsaspire.in
Time: Mon – Sat (10:00 – 19:00)