Scope

This Privacy Policy sets out the requirements for ensuring that we Capup Financial Services Private Limited “Capup” (formerly known as Pupil Finance private Limited) collect, use, retain and disclose personal information in a fair, transparent and secured way. This Privacy Policy is applicable to the personal information (including sensitive personal data or information) of:

• Capup’s customers,
• Users of the website, mobile applications (if any), and social media accounts of Capup,
• Third party vendors, or
• Any other persons that are associated with Capup for any business-related transactions / communications.This Privacy Policy is not applicable to independent data held by third-parties, but will continue to be applicable to:

• Personal information collected or processed by third parties on behalf of Capup
• And Personal information of third-parties collected by Capup.By accessing or using this website or services provided by Capup, you agree to be bound by the terms described herein and all the terms incorporated by reference.

      If you do not agree to all of these terms, do not use this website or services provided by Capup.

Objective

As Capup collects, receives, possess, stores, deals or handle information of provider of information in the course of offering or providing various products and services, either in person or via online digital channels to the Users, this Policy is framed and implemented for handling of or dealing in personal information including sensitive personal data or information of such Users and ensuring that the Users are able to review and consent to the Policy before providing their personal information to Capup.

Key Privacy Policy Principles
The Privacy Policy represents the minimum standards that Capup has set with respect to protection of data on Personal information, which refers to any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with Capup, is capable of identifying such person. Personal information includes sensitive personal data or information.

The personal information (including sensitive personal data or information) collected by Capup includes:

• Name
• PAN card number
• Driver’s license number
• Bank Account number
• Passport number
• Email Address
• Aadhaar Card
• Account statements
• Any other personal information (including sensitive personal data or information) received by Capup for processing, stored or processed by Capup under lawful contract or otherwise.

Capup values the personal information entrusted to it and the NBFC is committed to collecting, using, retaining and disclosing personal information in a fair, transparent and secure way by adhering to the following key principles:

1. Collection Limitation:Personal information shall be collected by fair, lawful and transparent means. Capup shall be open with individuals about how the NBFC will use their personal information, with whom it will be shared and where it may be sent.

• Consent shall be taken in writing or electronically from the provider of the sensitive personal data or information regarding purpose of usage before collection of such information.
• While collecting the personal information directly from the concerned person, Capup shall take reasonable steps to ensure that the provider of information is aware of the following aspects:
  – The fact that personal information is being collected
  – The purpose for collecting such information
  – The intended recipients of such information
  – The name and address of entities who are collecting and retaining such information.

The provider of information shall, at any time while availing the services or otherwise, also have an option to withdraw its consent given earlier to Capup. Such withdrawal of the consent shall be sent in writing to Capup on address (3rd Floor, 4th Cross Road, Behind Shivaji Talkies, Bangalore 560002) or through email- support@capupnow.com. In case the provider of information withdraws his / her consent in relation to personal information, Capup shall evaluate the request and take appropriate action. If an individual does not provide their personal information or subsequently, withdraws consent in relation to personal information, Capup shall have the option not to provide services for which the said information was sought. Capup may retain some data to meet its obligations under applicable law.

1. Data Minimization: Only personal information required for authorized business activities shall be collected from the information provider. Personal information shall not be made available to anyone (including internal staff) who is not authorized, or does not have a business need to know the information.
2. Purpose of collection: As per regulatory requirement we collect personal information for performing KYC of the customer, bank account statements are collected to establish credit worthiness of the customer, bank account details are collected for collection of dues/loan repayment. Other information’s are collected for the purposes of background verification etc.
3. Use Limitation: The personal information shall be used for the purpose for which it has been collected. The privacy risks shall be taken into consideration, before the collection, use, retention or disclosure of personal information, such as in a new system or as part of a project
4. Security: There shall be adequate protection for the personal information collected, used, retained and disclosed to support our business activities by following the relevant usage, technical and organizational policies, standards and processes.
   
   Capup has comprehensive documented information security program that contain managerial, technical, operational and physical security control measures. However, Capup will not be responsible for any loss, unauthorized access or any harm caused to the information provider by any misuse of his or her personal information. The information provider hereby acknowledges that Capup will not be responsible, in particular, for any third party action or action on the part of the information provider leading to loss, damage or harm to such information provider or any other person.

1. Access, Correction and Update: Processes shall be defined to enable the providers of information, as and when requested by them, to review the information they had provided and ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient shall be corrected or amended as feasible. Capup shall not be responsible for the authenticity of the personal information or sensitive personal data or information supplied by the provider of information. Capup shall ensure that the data provided by customers is correct through verification of documents submitted by them as per process laid out in the ‘ KYC Policy’.
   To review, correct or update their personal information, customers can write to us at-support@capupnow.com or reach out to us on our address at 3rd Floor, 4th Cross Road, Behind Shivaji Talkies, Bangalore 560002.
2. Retention: Sensitive personal data or information shall be retained no longer than required, to support a specific business activity or legal or regulatory requirement.
3. Disclosure: The personal information (including sensitive personal data or information) collected or stored by Capup, may be disclosed to comply with applicable law, directions from Government agencies mandated under law for prevention and investigation of offences, or to comply with an order issued by a competent court.
4. Transfer of Personal Information to Third-Parties: Adequate protection mechanism shall be provided for personal information in case it is transferred outside Capup’s network.

Capup may transfer sensitive personal data or information to any other entity or person located in India or any other country that ensures the same level of data protection that is adhered to by Capup.

Transfer of information shall be allowed only if it is necessary for the performance of lawful contract entered into between Capup or any person on its behalf and the information provider or where the information provider has consented to such transfer.

Personal information, including sensitive personal data or information, may be disclosed or transferred to insurance providers, credit bureau, verification agencies, collection partner, Regulatory & legal authorities (Credit information agencies, law enforcement agencies, judicial agencies), affiliates and business partners.

Reasonable due diligence activities shall be conducted to ensure that the third party has appropriate security & privacy controls in place prior to sharing of any personal information (including sensitive personal data or information).

Marketing and Promotional Activities: Marketing and promotional communications shall be sent to providers of information / customers only after obtaining required consent from them in adherence to obligations under applicable law.

Grievance Officer

The grievances or discrepancies reported by provider of information with respect to processing of personal information shall be addressed in a time bound manner by the designated ‘Grievance Officer ’. Customers can write to us at nodal@capupnow.com or reach out to us on our address at 3rd Floor, 4th Cross Road, Behind Shivaji Talkies, Bangalore 560002 

Grievance Officer Details:
Mr. Mr. Shiva Kumar M.C                      
Capup Financial Services Private Limited,
3rd Floor, 4th Cross Road, Behind Shivaji Talkies,
Bangalore 560002 

Third Party Websites & Services
Capup’s website and services may contain links to third party services, and give the user the ability to access such third-party websites, products, and services. Please proceed to the use of such third party website or service at your own risk. Capup will not be held liable for any outcome or harm arising as a result of such use of such third party websites or services. Please read the privacy policies of any third party before proceeding to use their websites, products, or services.

No Contractual Obligation
Please note that this Privacy Policy does not create any contractual or other legal rights in or on behalf of any party, nor is it intended to do so.

Changes to this Privacy Policy
Capup may periodically revise or update this Privacy Policy. Continued use of Capup’s website and / or services after the effective date of the Privacy Policy means that the user accepts the revised Privacy Policy. If the user does not agree with any such revised terms, please refrain from using Capup’s website and / or services