Last updated: 29 Dec 2022
Aspire Fintech Private Limited (“our”, “us”, “we”, “Company”, “Aspire”), a private limited company having its registered office at 1st Floor, Block B, Cowrks Yelahanka, Sy No 144, Bellary Road, RMZ Galleria, Ambedkar Colony, Yelahanka, Bangalore – 560064 Karnataka, India, owns and operates the website www.letsaspire.in and/or the mobile application ‘Aspire Pay Later > Credit Card’ (collectively referred to as the “Platform”) 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”).
This Privacy Policy (i) is an electronic record under the Information Technology Act, 2000 read with rules and regulations made thereunder 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 (“Aspire” or “We” or “Us” or “Our” or the “Company”) and our partnered banking/non-banking companies (“Lending Partners“) 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.
We have appointed a data grievance officer. Our data grievance officer is: Manoj Kumar Rathi, accessible via email at: compliance@letsaspire.in. You can contact the grievance officer by email If You have any grievance with respect to the Platform or the Services .
By using the Platform, you consent to providing us and our Lending Partner, 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:
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 Website or App, you must provide us with certain basic information required to provide customized services. When you use our Platform, whether our Website or our App, 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:
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 our Lending Partners 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 Know Your Customer (KYC) Registration Agency (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 by Lending Partners for providing 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 by our Lending Partners.
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
We seek explicit permissions from you to receive information about your location, your IP address and/or your mobile device, including a unique identifier number for your device 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.
STORAGE
We require the storage information permission that allows the App to enable you to upload photos and/or documents to complete the application form during your loan application journey.
We require storage permission so that your KYC and other relevant documents can be securely downloaded and saved on your phone. You can then easily upload the right KYC related documents for faster loan application details filling and disbursal process. This ensures that you are provided with a seamless experience while using the application.
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.
COLLECTION OF DEVICE INFORMATION
The information the App collects, and how that information is used, depends on how you manage your privacy controls on your device.
When you install the App, we store the information we collect with unique identifiers tied to the device you’re using.
We collect information from the device when you download and install the App and seek your explicit permission to get the required information from the device.
The information we collect from your device includes the unique ID i.e. IMEI number, information on operating system, SDK version and mobile network information including carrier name, SIM Serial and SIM Slot, your profile information, list of installed apps, wi-fi information.
We collect information about your device to provide automatic updates and additional security so that your account is not used in other people’s devices. In addition, the information provides us valuable feedback on your identity as a device holder as well as your device behaviour, thereby allowing us to improve our services and provide an enhanced customized user experience to you.
All information collected from you Including your Personal Information, non-personal Information, device Information, financial information etc. pursuant to this Privacy Policy shall be referred to as “User Information”
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 product to you, we will provide you the ability to opt-out of such uses.
We also use your Personal Information to:
In our efforts to continually improve our product and service offerings, we collect and analyze demographic and profile data about our users’ activity on our Platform.
USE OF YOUR DEVICE INFORMATION
We use the information provided by You in the following ways:
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 Lending Partners and our registered third parties including our regulated financial partners for provision of services on the Platform and/or for facilitation of a loan / facility to a User. 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:
In case we use or disclose your information for any purpose not specified above, we will take your explicit consent.
LINK TO THIRD-PARTY SDK
Our Platform has a link to a registered third party SDK which collects data on our behalf and data is stored to a secured server to perform a credit risk assessment. We ensure that our third party service provider takes extensive security measures in order to protect your Personal Information against loss, misuse or alteration of the data.
Our third-party service provider employs separation of environments and segregation of duties and have strict role-based access control on a documented, authorized, need-to-use basis. The stored data is protected and stored by application-level encryption. They enforce key management services to limit access to data.
Furthermore, our registered third party service provider provides hosting security – they use industry-leading anti-virus, anti-malware, intrusion prevention systems, intrusion detection systems, file integrity monitoring, and application control solutions.
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:
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:
Data transfers
We or our affiliates maintain your information on servers located in India Data protection laws vary among countries, with some providing more protection than others. We also comply with certain legal frameworks relating to the transfer of data as mentioned and required under the Information Technology Act, 2000.
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.
Bureau Enquiry
Our Lending Partners will enquire with one or more Credit Bureaus on one or more affiliate National Banking Financial Company’s (NBFC) behalf to provide you with your loan amount.
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 using the Platform and consenting to this Privacy Policy and/ or by providing your information, you 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.
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.
| Type of Data | Data Retention Period |
| Personal Information | End of your relationship with Us + 3 years |
| KYC-related information | End of your relationship with Us + 3 years |
| Information generated through one time access to camera and microphone | End of your relationship with Us + 3 years |
| Location-based information | End of your relationship with Us + 90 days |
| Information generated through one time access to storage | End of your relationship with Us + 3 years |
| Non-personal Information | As required under applicable laws |
| Other communications | End of your relationship with Us + 3 years |
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:
(i) Our IT department is responsible for deleting or destroying electronic records. This includes ensuring that the Personal Information and other information is permanently removed and from company system and destroyed.
(ii) 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.
(iii) When retention requirements have been met, Personal Information and other information shall be immediately destroyed.
(iv) 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: Aspire Fintech Pvt Ltd, 1st Floor, Block B, CoWrks Yelahanka, Sy No 144, Bellary Rd, RMZ Galleria, Ambedkar Colony, Yelahanka, Bangalore 560064
Phone: +91 6362 098 268
Email: compliance@letsaspire.in
Time: Mon – Sat (10:00 – 19:00)