Customer Support & Grievance Redressal

Purpose & Objective

ARTH “Arthimpact Digital Loans Private Limited” values the experience of the customers and strives to ensure that customers are always presented with excellent services. In addition to the experience of the customer, ARTH also understands the value of the public approaching us for products and services being offered, hence such prospects also considered to be our customers.

The Customer Support & Grievance Redressal Policy (CSGR) has been established to outline the uniform standards and operating procedures followed for appropriate experience of the customers and prospect public. Policy aims to address the Queries, Requests, or Complaints (QRC) by

  • acknowledge the QRC and feedbacks received
  • maintaining the records of the interactions
  • providing resolution to the complaints or grievances
  • ensuring in TAT close looping with the customers
  • analyze and review the QRC at suitable intervals
  • proposing the amendments as and when required for improving the CSGR mechanism

RESPONSIBILITY OF BOARD

  • To lay down appropriate grievance redressal mechanism at ARTH which ensure all disputes arising out of the decisions at ARTH are heard and disposed of at least at the next higher level
  • Periodical review of the functioning of Customer Support & Grievance Redressal mechanism. A consolidated report of such reviews shall be submitted to the Board at regular interval, as may be prescribed by it
  • To ensure that they and the LSPs engaged by them shall have a suitable nodal grievance redressal officer to deal with FinTech/digital lending related complaints/issues raised by the borrowers

RESPONSE STANDARD

To accomplish the mission of excellent experience of the customers or prospects, following values has been agreed upon:

  • Commitment to deliver highest level of experience and satisfaction of customers
  • Respecting the dignity of the customers
  • Ensuring the honesty while presenting any information deemed necessary
  • Engaging with the customers with various possible channels seems suitable for customer satisfaction 

TECHNOLOGY

Customer Support & Grievance Redressal Departments or Personnel at ARTH are empowered with Customer Relationship Management system for recording the QRC or Feedbacks or Grievances received through various channels (internal or external), further, to analyze & respond to the customers within the assigned TAT.

Further respective departments or personnel has been provided with tools to interact with the customers through Voice Calls, Emails and Whatsapp, we may reach out to the customers through these mode(s) according to customer preference or satisfaction.

Customer support

Customers with any query, request, complaint, or feedback may reach out to Customer Support Desk through 

Customers are requested to quote below information while reaching out to Customer Support Desk for identification and helping us in providing the necessary resolution within the agreed timelines.

  • Loan ID / Loan Account Number / Bureau ID
  • Registered Mobile Number
  • Comprehensible details of query, request, complaint, or feedback

Customer Support Desk shall acknowledge the customers within 7 working days followed by the resolution within 10 working days. 

Customer Support Desk shall be functional throughout the year except the National Holidays (or any other Non-functional days declared by Government or Government Regulated Bodies) and alternate non-banking Saturdays according to below timelines

  • Monday to Saturday
  • 10:00 AM to 07:00 PM

Customers are requested to quote below information while reaching out to Customer Support Desk for identification and helping us in providing the necessary resolution within the agreed timelines.

  • Loan ID / Loan Account Number / Bureau ID
  • Registered Mobile Number
  • Comprehensible details of query, request, complaint, or feedback

Customer Support Desk shall acknowledge the customers within 7 working days followed by the resolution within 10 working days.

Customer Support Desk shall be functional throughout the year except the National Holidays (or any other Non-functional days declared by Government or Government Regulated Bodies) and alternate non-banking Saturdays according to below timelines

  • Monday to Saturday
  • 10:00 AM to 07:00 PM

Grievance Redressal

Grievance Officer at ARTH has been assigned with the responsibilities to provide the resolution to the customers, analyze the feedback received & implementation of measures to improve the support offered by Customer Support Desk.

Customers are requested to reach out to Grievance Officer on following occasions:

  • Queries, requests, or complaints not acknowledged or resolved by Customer Support Desk within the assigned timelines
  • Unsatisfactory response to the queries, requests, or complaints
  • Feedbacks may help in improving the Services, Products or Support offered by ARTH

Grievance Officer can be reached out through 

Grievance Officer can be contacted throughout the year except the National Holidays (or any other Non-functional days declared by Government or Government Regulated Bodies) and alternate non-banking Saturdays from Monday to Saturday between 10:00 AM to 07:00 PM.

Customers may expect the acknowledgement to the voice raised to Grievance Officer within 3 working days followed with resolution in 5 working days. Customers are requested to make available following information while connecting with Grievance Officer.

  • Loan ID / Loan Account Number / Bureau ID
  • Registered Mobile Number
  • Comprehensible details of query, request, complaint, or feedback

Customers may also reach out to Grievance Officer Complaints pertaining to inappropriate behavior or harassments from any person engaged with ARTH directly or indirectly or associated partners, such Grievance shall be handled with utmost priority, customer may expect the revert or resolution within 3 working days.

Customers not satisfied with the Redressal of the Grievance may lodge the complaint to regulators through a centralized complaint management system under the Integrated Ombudsman Scheme, 2021. Following are the ways through which the complaint can be lodged.

  • Visit the website – https://cms.rbi.org.in
  • Calling Helpline Number – 14440
  • Email at crpc@rbi.org.in
  • Sending physical complaint to Centralized Receipt and Processing Centre (CRPC), RBI, 4th Floor, Sector 17, Chandigarh, 160017

Disclaimer

  • Customers reaching out to ARTH beyond or before the aforesaid functional timelines of Customer Support Desk or Grievance Officer may expect delay in response, however our representatives will always attempt to reach you back
  • Customers may be asked to provide the details pertaining to their records in our system for verification purpose
  • Customer unable to share the aforesaid details required for successful identification of the customer or the details of the services availed by the customer may see delay in resolution to their queries, requests, or complaints
  • On several instances, resolution to the queries, requests, complaints, or grievances may require follow-up, referrals internally or externally or from the customers, hence in such scenarios resolution to the grievance may take more time than aforesaid TAT
  • Customer reaching to Customer Support Desk or Grievance Officer approves & authorize our representatives to connect with the customers through Email, Whatsapp, SMS or through voice calls during aforesaid functional hours even if the contact number(s) available with us are registered in DND or DNC or NDNC register
  • Customers authorize ARTH to keep the record of the conversations or details provided while interacting with our representatives, however respective data shall always be confidential, for more details please refer to our Privacy Policy
  • ARTH Customer Support and Employees of ARTH does not provide assistance through Social Media Handles and platforms like Facebook, Instagram, Telegram, Twitter, Youtube, LinkedIn, hence customers are hereby requested not to engage with any individual or group of individuals, for support or services please reach out to us through aforesaid channels. ARTH might send notifications to the customers with important information through SMS or Whatsapp as and when necessary
  • Customer can visit official website for Products and Services offered by ARTH and can share their enquiries here, for enquires pertaining to Careers or Partnerships please reach out to us through Contact Us with relevant details, our representatives will get back to you.

Terms of Use

This document is an electronic record in terms of the Information Technology Act, 2000 and rules made thereunder as applicable and the amended provisions pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signatures.

This document defines ARTH’s reservation on all the rights under intellectual property law on the Website and in any content that is on the Website or in the Services. Website www.arthimpact.in owned and operated by Arthimpact Digital Loans Private Limited, , a Private Limited company incorporated under the provisions of the Companies Act, ‘2013 having Corporate Identification Number U65921MH1996PTC311634 and having its office at 210, The Empire Business Centre, 414, Senapati Bapat Marg, Lower Parel, Mumbai – 400013, India. These Terms of Use forming part of declaration shall constitute a valid and binding legal agreement between ARTH and yourself, The User. You are requested to read these Terms of Use before Registering, Accessing, browsing, downloading or using anything from the Website.

Ownership

“ARTH” reserves all rights under intellectual property law on the Website and in any content that is on the Website or in the Services. Except as we may expressly state in writing, you shall not reproduce, reprint, publish, or otherwise exploit content or technology from the Website. Republishing any content or technology from the website would attract penal provisions against the individual and/or the entity.

User’s Acceptance

    • The User agrees to authorize ARTH to retrieve and verify information including personal information, documents etc. submitted by the User or any other information procured by ARTH for the application of loan, credit, insurance, or other financial services.
    • The User authorizes ARTH to exchange/disclose all or any information relating to the User as well other information such as loan application, defaults, security, etc. with Reserve Bank of India and / or any other agency authorized by Reserve Bank of India credit bureau, affiliates, rating agencies, other banks, financial institutions, or any regulatory, supervisory or other authority, court of law, tribunal, in India or any other jurisdiction, where such disclosure is required by law, regulation, judgment or order of court or order of any tribunal, any third parties, any assignees/potential assignees, or transferees, who may process and publish the information in manner through mediums as it may be deemed necessary
    • The User authorizes ARTH to share the customer’s Data with any co-lending partner of ARTH for the following purposes:

    1. Collection, storage, preservation, analysis, publishing and dissemination, at any time, of all the customer Data, as the case may be;
    2. Verification or authentication of customer Data, making related enquiries on the basis of the customer Data for the purpose of assessing eligibility for loan and/or value added services opted/ availed by users from/ through ARTH and any co-lender; and

    • The submission of loan application does not imply automatic approval and ARTH at its sole and absolute discretion may either sanction or reject the application for granting a loan, credit, insurance, or other financial services. In case of rejection, ARTH is not under any legal obligation to mandatorily disclose the reason.
    • User agrees that the funds obtained from ARTH shall be used for the purpose for which loan has been applied for and will not be used for speculative or antisocial purposes.
    • User confirms that the information provided to ARTH is correct and accurate.
    User authorizes ARTH to connect via various modes of communication including and not limited to Calls, email, or SMS. Users also agree and authorize ARTH to connect with them irrespective of registration with DNC or NDNC Registry.

Right to Use Information

By providing any information through this Website, the User hereby grants the right to use such information for providing the Services. This consent will override any “Do Not Disturb” (DND) preferences set at User’s end with their telecom service provider.

Indemnity

The User agrees to defend, indemnify, and hold harmless “ARTH” and its, parent/subsidiary and affiliates, its employees, contractors, officers, directors and agents from all liabilities, claims, and expenses, including attorney’s fees, that arise from:

  1. Use or misuse of this Website; Violation of any condition of Terms of Use, including without limitation, Your representation and/or warranty.
  2. Violation of any third party right, including without limitation any copyright, trademark, trade secret or other property, or privacy right.
  3. Any claim that caused damage to a third party.

     

“ARTH” reserve the right, at our own expense, to assume the exclusive defense and control of any matter otherwise subject to indemnification by User, in which event the User will co-operate in asserting any available defenses.

Governing Law

If any dispute arises between “ARTH” and “User” in connection with or arising out of the validity, interpretation, implementation, or alleged breach of any provision of the Policy, such dispute shall be referred to and finally resolved by arbitration in accordance with the Indian Arbitration and Conciliation Act, 1996 for the time being in force, which rules are deemed to be incorporated by reference in this clause. The courts at Mumbai shall have exclusive jurisdiction in relation to any disputes arising out of or in connection with this Terms of Use.

There shall be one (1) arbitrator as appointed by “ARTH” and the seat of the arbitration shall be Mumbai, India. The language of the arbitration proceedings and of all written decisions and correspondence relating to the arbitration shall be English.

Severability & Assignment

If any part of these Terms of Use is held invalid or unenforceable, that portion shall be construed in a manner consistent with applicable law to reflect, as nearly as possible, the original intentions of these Terms of Use and the remaining portions shall remain in full force and effect. User shall not assign any rights or obligations, or liabilities created hereunder to any third party, however ARTH reserves the right to assign any right or obligations or liabilities to any third party.

Fair Practice Code

Introduction

The FPC is made to ensure fairness and transparency in dealings with the customers of ARTH and applies to all products and services offered by it.

Purpose & Objective

This Fair Practice Code (“FPC” or the “Code”) is framed in accordance with the guidelines outlined in the Master Direction DNBR.PD.007/03.10.119/2016-17 and Circular DOR(NBFC)(PD)CC. No.112/03.10.001/ 2019-20 issued by the Reserve Bank of India. This FPC is made with the intent to ensure fairness and transparency in dealings with the borrowers/customers of Arthimpact Digital Loans Private Limited (“ARTH” or the “Company”) and applies to all products and services offered by it. All employees, management, and the Board of ARTH are bound by this FPC. The Code, as revised from time to time, will be available on the website for information of various stakeholders.

Key Commitment

An extensive process has been devised for the Verification & Profiling of the beneficiaries and Disbursement of the grants.

ARTH will act under the FPC to ensure the fulfilment of all its following social/business goals:

  1. livelihood support
  2. micro-enterprise finance
  3. hyper-local economy development
  • The company will make sure all its dealings are based on principles of integrity and transparency
  • The company will make sure all the products and services are in line with relevant laws and regulations
  • Company ensures to promote good practices and ensure good practices in dealing with borrowers of the Company (“Customers”)
  • Company ensures to promote a fair relationship between the Customer and the Company
  • To ensure compliance with legal norms in matters relating to recovery of advances
  • To strengthen mechanisms for redressal of customer grievances

Guidelines

This FPC applies to the following areas:

  1. Applications for loans & their processing
  2. Loan Appraisal and terms/conditions
  3. Disbursement of loans including changes in terms and conditions
  4. Rate of Interest charged
  5. Customer Grievance Redressal
  6. Technology
  7. Client Protection

1. Application for Loans and Processing

  • As a part of lending activity, loans will be provided to customers for their business requirements ranging from small to medium-sized enterprises
  • All communications to the borrower shall be in the vernacular language or a language as understood by the borrower
  • Communications to the customers prior to the disbursement of the loan about the fees/charges if any, payable for processing, prepayment options, and any other matter which affects the interest of the borrower
  • Company shall communicate the customers about the rejection of the application of the loan
  • Loan products advanced through DLAs and/or LSPs are subject to further disclosures / requirements as mentioned below:
    1. Key Fact Statement (KFS) in the format provided in the Digital Lending Guidelines dated September 2,2022 issued by the RBI in respect of the digital loan product shall be provided to the Customer prior to sanctioning and disbursing the loan
    2. An all-inclusive cost expressed in ‘Annualized Percentage Rate’ (“APR”) shall be provided to the Customer. APR is the effective annualized rate charged to the borrower of a digital loan. APR shall be based on an all-inclusive cost and margin including cost of funds, credit cost and operating cost, processing fee, verification charges, maintenance charges, etc., and exclude contingent charges like penal charges, late payment charges, etc.
    3. The Company shall disclose the names of the LSPs, DLA on its website, digital loan product information, details of LSPs acting as collection agents, etc.
    4. No information (including personal information or data of the borrowers) shall be collected by LSPs / DLAs without the prior explicit consent of the borrowers
    5. The Company shall ensure that the LSPs / DLAs put in a place a comprehensive policy compliant with applicable laws and associates’ regulations in relation to collection of data (including personal data and information) in respect of the borrowers
    6. All data collection by the Company is stored in the servers located in India

2. Loan Appraisal and Terms& Conditions

    • ARTH would convey to the borrower the amount of loan sanctioned along with the terms and conditions including annualized rate of interest, and the borrower’s acceptance of these terms and conditions will be obtained and a kept in records
    • A copy of the loan agreement along with a copy of each of all enclosures quoted in the loan agreement will be furnished to the borrower at the time of disbursement of the loan
    • ARTH would conduct a credit assessment of all the loan application(s) in line with the credit policy and relevant regulatory guidelines issued by RBI or any other statutory authority
    • In relation to the digital loan products, the Company shall ensure the following:
    1. The Company shall capture the economic profile of the Customers (age, occupation, income, etc.), before extending any loan over their own DLAs and/or through LSPs engaged by them, with a view to assessing the Customer’s creditworthiness in an auditable way
    2. The Company shall ensure that there is no automatic increase in credit limit unless explicit consent of Customer is taken on record for each such increase

3. Disbursement of Loans Including Changes in Terms & Conditions

  • ARTH would ensure the timely disbursement of loans in accordance with the terms and conditions governing such sanctions
  • The company shall give notice to the borrower in the vernacular language or a language as understood by the borrower of any change in the terms and conditions including interest rates, service charges, etc.
  • ARTH also ensures that changes in interest rates and charges shall be affected only prospectively
  • Any decision to recall/accelerate payment shall align with the loan agreement

4. Rate of Interest Charged

  • The rate of Interest, processing fee, and any other charges would be determined based on relevant factors such as cost of funds, margin, risk premium, etc.
  • The rate of interest and the approach for gradation of risk and rationale for charging different rates of interest for different categories of borrowers, wherever applicable, shall be disclosed prior to the disbursement of the loan
  • The APR shall be presented to the customer which shall include the Rate of Interest levied on the sanction loan, to make the borrower aware of the exact rates that would be charged to their account
  •  

5. Customer Grievance Redressal

  • ARTH has a well-laid-out Grievance Redressal Mechanism to resolve disputes raised by customers
  • Details of the Grievance Officer of the Company, for the benefit of the customers, would be displayed on the website and Loan Agreement, to facilitate the borrower with effective Grievance Redressal
  • In case the complaint/ dispute is not redressed within one month, the customer may appeal to:

Officer-in-charge:

Department of Supervision,

Reserve Bank of India,

Central Office, World Trade Centre, Centre I, Cuffe Parade,

Colaba, Mumbai – 400005

  Calling Helpline Number – 14440

  Email at crpc@rbi.org.in

 Sending physical complaint to Centralized Receipt and Processing Centre (CRPC), RBI, 4th Floor, Sector 17, Chandigarh, 160017

  • The Company shall ensure that the DLAs / LSPs appoint a suitable Nodal Grievance Redressal Officer to deal with fintech/ digital lending related complaints/ issues raised by the borrowers. The name and details of such officer along with the process of Grievance Redressal shall be set out on the website of the LSPs / DLAs.  

6. Technology

In line with the mandate of RBI, the Company has adopted and implemented the following requirements:

  1. The Company shall ensure that LSPs/DLAs engaged by them do not store personal information of the Customers except some basic minimal data (viz., name, address, contact details of the customer, etc.) that may be required to carry out their operations
  2. The Company shall carry out the responsibility of ensuring that the LSPs and DLAs maintain data privacy and security of the Borrower’s personal information
  3. The Company shall ensure that the Customer 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
  4. The Company shall ensure that any collection of data by their DLAs and DLAs of their LSPs is need-based and with prior and explicit consent of the Customers having audit trail. The Company shall also ensure that DLAs desist from accessing mobile phone resources like file and media, contact list, call logs, telephony functions, etc. 
  5. The purpose of obtaining borrowers’ consent needs to be disclosed at each stage of interface with the borrowers
  6. Explicit consent of the borrower shall be taken before sharing personal information with any third party, except for cases where such sharing is required as per statutory or regulatory requirement. 
  7. The Company shall ensure that clear policy guidelines regarding the storage of customer data including the type of data that can be stored, the length of time for which data can be stored, restrictions on the use of data, data destruction protocol, standards for handling security breach, etc., are put in place and also disclosed by DLAs of the REs and of the LSP engaged by the Company prominently on their website and the apps at all times
  8. The Company shall ensure that no biometric data is stored/ collected in the systems associated with the DLA of the Company / their LSPs, unless allowed under extant statutory guidelines
  9. The Company shall ensure that they and the LSPs engaged by them comply with various technology standards/ requirements on cybersecurity stipulated by RBI and other agencies, or as may be specified from time to time, for undertaking digital lending
  10. All data (including personal data and information of the Customers) shall be stored in India.  

7. Client Protection

  • In the matter of recovery of loans, the company will not resort to undue harassment
  • The company will ensure that its staff is adequately trained to deal with customers appropriately and respectfully
  • The company will treat the personal information of customers/borrowers as private and confidential even when they are no longer a customer. It will not reveal the personal information or details of the customers’ account to any third party, other than in the following four exceptional cases when required by law, or to protect against any kind of fraud, or with the customer’s permission or with third party on a need to know basis
  • In cases where the sourcing of clients is done by any external entity, complete care, and diligence shall be followed in ensuring that the entity follows appropriate client protection standards in consonance with this FPC

Review

This FPC and the functioning of the Grievance Redressal Mechanism shall be reviewed by the Board periodically and be modified to concerning changes in the company operating model, product and service offerings, external environmental factors, and modifications in the stated master direction & circular or any new introduction thereof. A consolidated report of the review of the FPC shall be submitted to the Board at regular intervals.

Implementation

The FPC shall be effective from the date of adoption by the Board

Amendment

Th FPC shall be amended and/or restated and updated from time to time and such amendments and/or restatements and updates shall be effective from the date of adoption by the Board.



Privacy Policy

Introduction

ARTH “Arthimpact Digital Loans Private Limited” recognizes the expectations of its customers with regard to privacy, confidentiality and security of their personal information that resides with the Company. Keeping personal information of customers secure and using it solely for activities related to the Company and preventing any misuse thereof is a foremost priority of the Company. The Company has adopted this privacy policy aimed at protecting the personal information entrusted and disclosed by the customers (hereinafter referred to as the “Policy”). This Policy governs the way in which the Company collects, uses, discloses, stores, secures, and disposes of personal information and sensitive personal data or information.

Definitions

“Digital Lending Apps” / “Platforms” / “DLA(s)” shall mean mobile and web-based applications with user interface that facilitate digital lending services. DLAs will include apps of the Company as well as those operated by LSPs engaged by the Company for extending any credit facilitation services in conformity with extant outsourcing guidelines issued by the RBI.

“LSP(s)” means an agent of the Company who carries out one or more of Company’s functions or part thereof in customer acquisition, underwriting support, pricing support, servicing, monitoring, recovery of specific loan or loan portfolio on behalf of the Company in conformity with extant outsourcing guidelines issued by the RBI.

“Personal Information” means any information that relates to a natural person, which is capable of identifying such person, either directly or indirectly, either independently or in combination with other information, either available or likely to be available with the Company.

“RBI” shall mean Reserve Bank of India.

“Sensitive Personal Data or Information” of a person or business legal entity means such personal / business information which consists of information relating to any or all of the following:

  1. Password;
  2. financial information such as details pertaining to a Bank account or credit card or debit card or any other payment instrument;
  3. physical, physiological, and mental health condition;
  4. sexual orientation;
  5. medical records & history;
  6. biometric information;
  7. any detail relating to the above clauses as provided to the Company for providing service, or received by the Company for processing, stored or processed under lawful contract or otherwise. 

Provided that the following shall not be regarded as sensitive personal data or information for the purposes of this policy:

  1. any information that is freely available or accessible in the public domain or furnished under the Right to Information act, 2005 or any other law for the time being in force;
  2. information obtained from a business legal entity in addition to “personal information”;
  3. Know Your Customer (KYC) and other information provided by the customer at the time of commencing a relationship or any time thereafter;
  4. information about transactions with the Company;
  5. has been obtained by the Company from a third person without any obligations of confidentiality;
  6. furnished pursuant to any directions of a governmental authority or court of law;
  7. was rightfully in the Company’s possession prior to receipt from the customer free of any obligation of confidence.
  1. any information that is freely available or accessible in the public domain or furnished under the Right to Information act, 2005 or any other law for the time being in force;
  2. information obtained from a business legal entity in addition to “personal information”;
  3. Know Your Customer (KYC) and other information provided by the customer at the time of commencing a relationship or any time thereafter;
  4. information about transactions with the Company;
  5. has been obtained by the Company from a third person without any obligations of confidentiality;
  6. furnished pursuant to any directions of a governmental authority or court of law;
  7. was rightfully in the Company’s possession prior to receipt from the customer free of any obligation of confidence.

Applicability

This Policy is applicable to Personal Information and Sensitive Personal Data or Information collected by the Company or its affiliates directly from the customer or through the Company’s online portals, mobile apps, and electronic communications as also any information collected by the Company’s server from the customer’s browser

Purpose & Objective

The Company collects and uses the Personal Information and Sensitive Personal Data or Information from its customers. This information is collected and used for specific business purposes or for other related purposes designated by the Company or for a lawful purpose to comply with the applicable laws and regulations. The Company shall not divulge any Personal Information or Sensitive Personal Data or Information collected from the customer, for cross-selling or any other purpose. This Policy serves to outline the privacy measures followed by the Company to safeguard the data entered by customers on its web portal and application. The authenticity of the Personal Information or Sensitive Personal Data or Information provided by the customer shall not be the responsibility of the Company.

The authenticity of the Personal Information or Sensitive Personal Data or Information provided by the customer shall not be the responsibility of the Company.

Disclosures of Personal Information

The Personal Information or Sensitive Personal Data or Information collected by the Company shall not be disclosed to any other organization except:

  1. where the disclosure has been agreed upon in a written contract or otherwise between the Company and the customer;
  2. where the Company is required to disclose the personal information to a third party on a need-to-know basis, provided that in such case the Company shall inform such third party of the confidential nature of the personal information and shall keep the same standards of information/ data security as that of the Company;
  3. furnished pursuant to any directions of a governmental authority or court of law;
  4. The inclusive list of the details of third parties (where applicable) allowed to collect personal information through the DLA will be updated from time to time.

In line with the mandate of the RBI, the Company has adopted and implemented the following requirements: 

  1. The Company shall ensure that LSPs/DLAs engaged by them do not store personal information of the customers except some basic minimal data (viz., name, address, contact details of the customer, etc.) that may be required to carry out their operations.
  2. The Company shall carry out the responsibility of ensuring that the LSPs and DLAs maintain data privacy and security of the customer’s personal information.
  3. The Company 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.
  4. The Company shall ensure that any collection of data by their DLAs and DLAs of their LSPs is need-based and with prior and explicit consent of the customers having an audit trail. The Company shall also ensure that DLAs desist from accessing mobile phone resources like file and media, contact list, call logs, telephony functions, etc.
  5. The Company shall ensure that the customer 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.
  6. The purpose of obtaining customers’ consent needs to be disclosed at each stage of interface with the customers.
  7. Explicit consent of the customer shall be taken before sharing personal information with any third party, except for cases where such sharing is required as per statutory or regulatory requirement.
  8. The Company shall ensure that clear policy guidelines regarding the storage of customer data including the type of data that can be stored, the length of time for which data can be stored, restrictions on the use of data, data destruction protocol, standards for handling security breach, etc., are put in place and also disclosed by DLAs of the REs and of the LSP engaged by the Company prominently on their website and the apps at all times.
  9. The Company shall ensure that no biometric data is stored/ collected in the systems associated with the DLA of the Company / their LSPs, unless allowed under extant statutory guidelines.
  10. The Company shall ensure that they and the LSPs engaged by them comply with various technology standards/ requirements on cybersecurity stipulated by RBI and other agencies, or as may be specified from time to time, for undertaking digital lending.
  11. All data (including personal data and information of the customers) shall be stored in India.
  12. No information (including personal information or data of the borrowers) shall be collected by LSPs / DLAs without the prior explicit consent of the customers.

Nothing stated above shall preclude the Company from adhere to the mandate of disclosing / reports borrowers to the credit information companies in accordance with the Digital Lending Guidelines and/or the Outsourcing Policies and/or other extant instructions / guidelines / directions / circulars of the RBI.

Reasonable Security Practices and Procedures

The security of Personal Information or Sensitive Personal Data or Information is a priority and will be protected by maintaining physical, electronic, and procedural safeguards that meet applicable laws. The Company shall take reasonable steps and measures to protect the security of the customer’s Personal Information or Sensitive Personal Data or Information from misuse and loss, unauthorized access, modification, or disclosure. The Company will maintain its security systems to ensure that the Personal Information or Sensitive Personal Data or Information of the customer is appropriately protected and follows the extant standard encryption norms followed for the transmission of information. The Company will ensure that its employees and affiliates respect the confidentiality of any personal information held by the Company.

Data Retention

Company is allowed to retain data for a longer period for the purpose set out in the policy and for legal or regulatory reason. Customer may withdraw its consent or request the deletion of its Personal Information or Sensitive Personal Data by writing to our contact information. Whatever data is captured on the website, would not be shared with any third-party for promotional and/or marketing purposes.

Exclusions

Notwithstanding anything mentioned in the Policy, the Policy shall exclude information that is needed to be shared with others due to extant regulations e.g. credit bureaus, Central KYC Registry, Registrar of Companies and the RBI, and also where the Company is legally bound to disclose information including but not limited to Financial Intelligence Unit, Enforcement Directorate, Income Tax  department or as required by a court of law or tribunal.

Contact Information

The Company shall have at all times during the tenure of this Agreement, a dedicated Customer Support and display the details of Customer Support on its website and on the DLA. In order to address any discrepancies or queries related to the personal information residing with the Company, the customer may write to support@arthdigital.net.

Customers not satisfied with the response or resolution from the Customer Support may write to Grievance Officer at grievance@arthdigital.net

The Website & DLA operated by the Company shall categorically provide the detail of the Customer Support & Grievance Redressal Mechanism established by the Company. 

Implementation

This Policy shall be effective from the date of adoption by the Board.

Amendment

This Policy shall be amended and/or restated and updated from time to time and such amendments and/or restatements and updates shall be effective from the date of adoption by the Board.

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Arthimpact Digital Loans Private Limited
Certifications
Group Financial Inclusion
ISO 9001:2015 & ISO 27001:2013 (ISMS) Certified