Privacy Policy

This Privacy Policy outlines S Assets Private Limited's approach to processing of Data.

At S Assets P Limited, we understand the significance of your personal data and process the same in a responsible manner. We urge you to go through this Privacy Policy attentively.

Who is covered by the Privacy Policy?

This policy is applicable to all the existing customers, prospect customers and persons ("User") who visit the office/ branch and/or any 'Digital Property' belonging to S Assets Private Limited ("SAPL") which offer services. If you are below 18 years of age, you are expected to view our Digital property under the guidance of a natural parent/legal guardian.

The reference made to the term Digital Property would mean and include website, mobile application and/or any other electronic application.

This Privacy Policy explains about the type of information of the User that SAPL collects, consent, its purpose, salient features etc. as detailed below. We encourage User to read this Privacy Policy regarding the collection, use, and disclosure of information by User from time to time to keep itself updated with the changes & updates that we make to this Policy.

Consent

By using our website/application/any other electronic application and by availing various products/services from SAPL, User consents to:

  1. The terms of this Privacy Policy in addition to the terms of use of mobile application, website, and product documents.
  2. Collection of data in connection with availing any of our services.
  3. Consent for collection of data in connection with Aadhaar based authentication (Aadhaar eKYC) or verification (Aadhaar OKYC) facility provided by UIDAI, to check/verify/download/obtain/upload/update KYC details from/with the Central KYC Registry (CERSAI), collection of data from Digilocker provided by MeitY (Ministry of Electronics and Information Technology).
  4. Communications relating to marketing & business promotions.
  5. Storage of data as may be required for regulatory and legal requirements.
  6. Consent for E Mandate Registration with eSignature.
Types of Information

This policy is applicable to any types of 'information' that is collected by SAPL:

  • which is in the nature of personal data of/ demographic information of the User provided to SAPL online or offline (i.e., Name, age, date of birth, gender, address, mobile number, email id, PAN number, photograph/image, KYC documents provided by customer or collected from CKYC registry/ Aadhaar Authority/ Digilocker, bank account details, credit scores, GST details, provident fund account details, provided to SAPL through mobile application, website and/or at the time of availing various products/services)
  • which may or may not be personally identifiable and/or traffic information;

For brevity's sake, the above type of information is collectively referred as "Information" in this Policy.

Sources of Information

Following are the sources of 'information' collected by SAPL:

  • From the User, during the product application journey, either online or offline.
  • From User's browser, mobile application, or mobile device, including cookies etc.
  • From its service providers, dealers, agents/agencies, including the server from the User's browser, mobile app, or mobile device.
  • Customer Information from Email with the consent of User as part of rendering Products / Services.
Purpose

Information collected from User may be used by SAPL for the following listed "Purposes":

  • To provide the User with the services incidental and/or ancillary to the business of SAPL
  • To promote the products/services of SAPL
  • For evaluation of the existing SAPL products/services, and/or develop products/services
  • To render service to User and/or to enhance/improvise the Products/Services
  • To comply with Applicable Laws/regulations, including credit reporting.
  • To the extent permitted by the terms of an agreement/Applicable Law/regulations, share or process User's information in connection with the products/services provided by SAPL.
  • To advertise exclusive offers, promotions, customized search results, and location-based services related to products or services.
  • To automatically populate third-party pages when you click on advertisements within app/website.
Cookies

Cookies are small details that a website stores on your computer/electronic device. While cookies have unique identification numbers, personal information (name, a/c no) SHALL NOT be stored on the cookies. SAPL may:

  1. Temporarily store the mobile number in the cookies, where the User submits the mobile number for a particular session and the same is deleted simultaneous with the session log off.
  2. Use persistent cookies which are permanently placed on User's computer to store non-personal (Browser, ISP, OS, Clickstream information etc.) and profiling information (age, gender, income etc.).
  3. Use information stored in the cookies to improve User experience by throwing up relevant content where possible.
  4. Use the cookies to store User preferences to ease User's navigation on the website/electronic/mobile application.
Salient Features
  • SAPL respects the privacy of User in accordance with prevailing Law/regulation that governs privacy and always strives to uphold the standards in protecting the same.
  • Except with its Service Providers, the Information shall not be shared with any external organization unless the same is necessary to enable SAPL to provide you services, meet legal and/or regulatory compliance requirements, and/or to enable the completion of a transaction, rendition of services, pursuant to applicable norms/process or pursuant to the terms and conditions applicable to such Information as agreed with SAPL.
  • SAPL may use the Information to enhance the User's experience and may make subsequent offers to the User about its products/services.
Data Governance and Trainings

At our company, we believe in maintaining transparency with our customers when it comes to data governance policies. As per our data privacy policy, data governance is one of our prime focus areas that help us deliver quality services to our customers. We follow stringent guidelines on data governance, which include factors such as data quality, data minimization, data accuracy, and data accessibility.

We understand that data privacy is a critical concern for our customers, and we ensure that we use the data provided only for specific purposes, adhering to the customer's consent given. Our employees handle customer data ethically and securely. Our employees follow various parameters like data classification, ethical handling of customer data, minimizing data exposure to third parties, and maintaining the confidentiality and privacy of data, among others.

Our data governance policies help us maintain transparency and accountability when handling customer data, and we strive to continuously update and improve our policies to ensure the safety and privacy of your data.

Security

Securing User's Information is of paramount importance to SAPL, and it undertakes the following initiatives to secure privacy of the User's Information:

  1. SAPL implements various reasonable management, technical, and administrative measures to safeguard internal information, with sound technical controls to secure the underlying systems.
  2. Alongside conducting periodic internal and external audits of systems, SAPL adheres to multiple regulatory and statutory obligations.
  3. SAPL has in place controls such as data discovery which ensures that personal data of User is tracked across all its assets and security of such data is ensured using data encryption and masking methodologies. Further, we have implemented access controls across all our data assets to ensure that employees have access to limited data and only on a need-to-know basis.
  4. SAPL has a robust IT infrastructure support mechanism that ensures all systems are updated to the latest system and security patches.

Our responsibility is to keep you informed of our approach to information security and encourage your commitment to its successful implementation.

Service Providers

We may employ third-party service providers and individuals due to the following reasons (not exhaustive):

  • To facilitate SAPL's products/services
  • To provide the service on behalf of SAPL
  • To perform any ancillary service related to products/services of SAPL and/or its Group
  • To assist SAPL in analyzing how the services are used
  • To assist SAPL and/or its Group in evaluating and improvising the service standards

User is hereby informed that the third-party service provider/agent/agencies will have access to your Information on a need-to-know basis to assist SAPL in rendering service and are restricted from using the same for any other reason other than specified during data collection. The third-party service provider is obligated not to disclose or use the Information for any other purpose.

Responsibility of User

User acknowledges the following:

  • SAPL and/or its employees/assigns will not contact the User directly for disclosure of any personal information unless required for the above-mentioned Purposes. Hence, User is solely responsible to exercise proper due diligence to verify the identity of the individual(s) contacting before disclosing any personal data/information by reaching out to SAPL's official customer care number accessible on its website.
  • SAPL will not be liable/responsible for any breach of privacy owing to User's negligence.
  • User shall only use the official website/links of SAPL for availing product/services by inputting the domain information on the address bar.
  • User is completely aware about the potential risk of data/privacy breach and shall be solely liable for any unauthorized disclosure/breach of personal information etc. and any direct/indirect loss suffered due to User's conduct. Hence, User shall exercise utmost caution to ensure that personal data (including but not limited to passwords, financial information, account details, etc.) are not shared/stored/made accessible through any of the following means:
  1. User shall always check if "https" appears in any website's address bar before making any online transaction, to ensure that the webpage is encrypted.
  2. User shall avoid using third-party extensions, plug-ins or add-ons on web browsers, as it may result in the risk of tracking or stealing of personal details.
  3. User shall always type the information and not use the auto-fill option on web browsers and mobile apps to prevent the risk of storing personal information.
  4. User shall NOT access darknet, unauthorized/suspicious/malicious websites, or download information from unreliable sources.
  5. User shall ensure to disable cookies before accessing any domain/website, unless consciously permitted by User; consequences of such permission will be User's responsibility.
  6. User shall not respond to any generic emails from unknown/unidentified sources.
  7. User shall check the Privacy Policy of websites/applications to know the type of information collected and how it is processed before proceeding with any transaction.
  8. User shall always verify and install authentic web/mobile applications from reliable sources on their electronic devices.
  9. User shall NOT access unidentified web links or electronic links shared via email, SMS, social media, or websites.
Data Storage, Retention, Handling and Destruction

SAPL shall retain/store User's Information in India if it is required to provide services or as long as it is required for business purposes. Retention of Information will be in accordance with applicable law and regulatory requirements in India.

Retention of Information

SAPL may retain the following kinds of information (not exhaustive):

Sl.No Kinds of Information Retention Period
1 KYC Documents (Identity and Address proof, and Account Opening Form) During the tenure of relationship and at least five years after cessation of the relationship
2 Loan Files containing documents like Application Form, Income Documents, agreements etc., collected at the time of opening During the tenure of relationship and five years from closure of loan
3 Customer Walk-in Complaint/Suggestion Register 5 years
4 All necessary records of transactions between the SAPL and the User 5 years from the date of transaction
5 Deceased Constituents A/c. (Death Certificates, Affidavits, Letters of Disclaimer, Succession Certificate copies, and any other correspondence) 8 years
Extended Retention & Secure Destruction

Information may be retained for an extended period:

  • In case of requirement of any investigations under law or as part of any requirement before Courts/Tribunals/Forums/Commissions etc.
  • To enhance or improve the products/services of SAPL.

SAPL ensures that access to User data is sufficiently restricted using access controls and industry standard encryption algorithms. Further, SAPL has in place a robust incident management system along with a proactive incident response posture. If retaining Customer Information is no longer necessary, we make every effort to securely destroy or delete it as per applicable regulations.

Website & Links to Other Sites

SAPL's website/electronic/mobile application may contain links to other sites. If User clicks on a third-party link, User may be directed to that site. It may be noted that such external sites are not operated by SAPL and are beyond its control. Therefore, SAPL strongly advises Users to review the privacy terms/policies of such external websites/electronic applications.

SAPL has no control over and assumes no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Amendment of Privacy Policy

SAPL may amend or update the Privacy Policy from time to time as required under law. Thus, Users are advised to review this page periodically for any changes, since any such changes will be effective immediately after they are updated or posted on this page.

Contact Us

In case you may want to share your concern, we welcome you to easily reach out to us.

Disclaimer
  1. The terms of specific agreements entered into with the respective Users relating to the product/service offering shall prevail in case of any inconsistency with respect to the information referring to SAPL products/services.
  2. All other information, such as images, facts, statistics etc. ("information") that are in addition to the details mentioned in the SAPL's product/service document and which are being displayed on this page only depict the summary of the information sourced from the public domain. The said information is neither owned by SAPL nor is it to the exclusive knowledge of SAPL. There may be inadvertent inaccuracies or typographical errors or delays in updating the said information. Hence, Users are advised to independently exercise diligence by verifying complete information, including by consulting experts, if any. Users shall be the sole owner of the decision taken, if any, about the suitability of the same.