Privacy Policy

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

Privacy Policy

Please read this Privacy Policy before using the application or submitting any personal information. By using CapUp, it shall be deemed that the User are expressly consenting to be bound by the terms and conditions described in this Privacy Policy.

1. Links to other websites

The procedures and practices set forth in this Privacy Policy describe the use and disclosure of User Information collected through CapUp Products. These CapUp Products may contain links to other websites. Any personal information about the User collected which such User visits such websites is not governed by this Privacy Policy. The User is encouraged to exercise caution and review the privacy policies applicable to such websites before accessing them. The User acknowledges that CapUp shall not be responsible for and has no control over the practices and content of any website accessed using the links contained on the CapUp Products.

2. Competency to contract

By agreeing to these Privacy Policy, a User (which such User is a natural Person) represents that the User is at least the age of majority i.e. 18 years, and is competent to contract. Additionally, where the User is registering on behalf of, and is the authorized representative of, a company, partnership or any other legal entity, such User has been duly authorized by such entity and is permitted under Applicable Laws to accept these Terms of Service. In case the User is a natural Person who is not of the age of majority or is not competent to contract, the User may not use the CapUp Products or provide any information to CapUp.

3. Collection of information

Towards the provision of the Services and in cases where a User visits or uses the CapUp Products, CapUp shall collect the following information from a User (“User Information”):

3.1. Information given by the User: The User may be required to give us information (including sensitive personal information) about the User when creating or using an account on a CapUp Product, or when corresponding with CapUp by phone, e-mail or otherwise. The information you give us may include without limitation your name, photograph, postal address, e-mail address and phone number, details of any identification or address proof, financial information, location details or other information required by CapUp to provide the Services and protect against any illegal activities. We may also require additional information about a User in compliance of or as required under Applicable Laws;

3.2. Information collected about a User: With regard to a User’s use of any CapUp Product, CapUp may automatically collect and analyse technical information such as the IP address, login information, browser details, time zone setting, operating system and other similar information; or information about a User’s visit such as URL information, material or information viewed or searched by the User; page response times, download errors, length of visits to certain pages, page interaction information, methods used to browse away from the page, metadata such as location, date etc., and details of email address or phone number used to contact customer service; and

3.3. Information we receive from other sources: CapUp may receive information about a User its other products and services used by the User or from third parties such as advertising networks, analytics providers, search information providers. CapUp may also collect non-personally identifiable information of Users.

4. Usage of User Information

User Information is used by CapUp and its partners and service providers towards various business purposes which, amongst others, includes:

   – to facilitate the User’s requests and the Services;

   – to undertake research and analytics for offering or improving Services, CapUp Products, their security and service quality;

   – to share with a User, updates on changes to CapUp’s services and their terms and conditions and provide details of similar products and services;

   – to aid strategic development, data collection and business analytics for CapUp;

   – to take up or investigate any complaints/claims/disputes;

   – to respond to your queries or feedback submitted by the User;

   – for conducting audits and for record keeping purposes;

   – for complying with Applicable Laws including the directions of any Governmental Authorities;

   – for selective offers and promotions; and

   – for providing a personalized experience and to enhance a User’s experience in relation to the application or the website.

   – for contacting you through WhatsApp, SMS, Email, or other means, on the contact number and email ID (made available by you on our Website/App), and offer you information and services for the product you have opted for. You authorize us to contact, call, SMS or email you for the mentioned purpose, irrespective of whether you register with the NDNC registry. CapUp may from time to time send by e-mail or otherwise, information relating to products and services offered by its partners and affiliates, general information related to financial and other services, and products.

5. Storage of User Information

User Information in the possession and control of CapUp is stored in accordance with Applicable Laws. By using any of the CapUp Products or Services, the User agrees and consents to the collection, storage and use of the User Information collected in the manner described in and in accordance with this Privacy Policy.

6. Dissemination of User Information

The User acknowledges the User Information and other data may be exported outside of India, processed and stored in a foreign country or countries where it may be accessed by other entities. User Information may also be transferred in accordance with Applicable Laws to Governmental Authorities, to affiliates of CapUp and any potential buyers of the shares or assets of CapUp. CapUp may also distribute User Information (not being in the nature of sensitive personal information) with other third parties, analytics providers and other third parties for provision of services to CapUp and/or the Users by such third parties.

7. Service Providers

CapUp may employ third-party companies and individuals due to the following reasons:

   – To facilitate our Service;

   – To provide the Service on our behalf;

   – To perform Service-related services; or

   – To assist us in analyzing how our Service is used

   – We want to inform users of this Service that these third parties have access to your Personal Information. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.

8. Information security

CapUp takes various steps and measures to protect the User Information provided by a User from misuse, loss, unauthorised access, modification or disclosure. Do note that while CapUp makes best possible efforts to securely store the User Information and data provided by a User, CapUp does not guarantee that there will be no unintended disclosures of the User Information and data provided by a User on account of a data breach, unauthorized access, security failure etc. CapUp cannot guarantee, give no warranties, and shall not be liable for breach of the security of User Information through the CapUp Products due to malicious attacks, errors, commission or omissions not willfully initiated by CapUp and any transmission is at the risk of the User.

9. Retention of User Information

CapUp may, at its discretion, retain any User Information for as long as a User is active on the CapUp Products, as required under agreements with CapUp or as required under Applicable Laws. CapUp shall not be responsible for any destruction of any User Information after the closure or termination of a User’s account with CapUp.

10. Cookie policy

Cookies are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to your browser from the websites that you visit and are stored on your device’s internal memory. This Service does not use these “cookies” explicitly. However, the app may use third party code and libraries that use “cookies” to collect information and improve their services. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to use some portions of this Service.

11. Contact details

In case a User has any queries or any discrepancies / grievances with respect to the Privacy Policy, do not hesitate to contact us.

12. Updates to the Privacy Policy

CapUp may update its Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. CapUp will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page.

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