Privacy Policy“12% Club” is the trademark of Resilient Innovations Private Limited, a
company
incorporated under the provisions of the Companies Act, 2013, having its registered office at 90/20 Malviya
Nagar, New Delhi-110017, India (“Company”). The Company is engaged in the business of,
inter alia, providing aggregator services to Users for receiving financial products and services
from
other partners.
Please note that by visiting 12Club.in or accessing the mobile
application titled “12%Club” you are accepting
the practices described in this Privacy Policy. All users of the mobile application (“Application”)/
website
(“Website”) are advised to read and understand our Privacy Policy carefully, as by accessing the
Application
you agree to be bound by the terms and conditions of the Privacy Policy and consent to the collection,
storage
and use of information relating to you as provided herein. By using the Application, you (“you”)
expressly
consent to 12% Club’s (“our” or “us”) use and disclosure of your personal information in accordance with
this
Privacy Policy. This Privacy Policy is incorporated into and subject to the Terms of Use which is
available at
https://12club.in/terms
Our Privacy Policy is subject to change from time to time
without notice and it is strongly
recommended that you periodically review our Privacy Policy as available on the Application/Website. In case
you
need any clarifications regarding this Privacy Policy, please do not hesitate to contact us at
Name:
Rajeev
Ranjan
Address: - A45,Second Floor, Corner Market, Malviya Nagar, Delhi 110017
Email:
support@twelve.club
[9:30 AM to 6:30 PM, Monday to Friday except Public
Holidays]
COLLECTION, STORAGE AND USE OF INFORMATION RELATED TO
YOU
We collect two basic
types of information from you in conjunction with your use of the Website/ Application i.e. personal
information, which is any information that exclusively identifies you (e.g., your name, email address,
telephone
number, postal address, credit card information amongst others) and non-personal information, which is
information that does not exclusively identify you but is related to you nonetheless such as, information
about
your interests, demographics and use of the sites.
We may automatically track certain information
about you based upon your behaviour on the Application/ Website. We use this information to do internal
research
on our users' demographics, interests, and behaviour to better understand, protect and serve our users.
This information is compiled and analysed on an aggregated basis. This information may include the URL that
you
just came from (whether this URL is on our website or not), which URL you next go to (whether this URL is on
our
website or not), your computer browser information, your IP address, and other information associated with
your
interaction with the Application/ Website.
Please note that the Company collects, processes,
stores
and uses any information in compliance with Indian laws, including without limitation, the Information
Technology Act, 2000. In case you are a resident or a citizen of a country other than the Republic of India
and
are, therefore, subject to additional and different requirements for data security, storage, processing or
use
(such as requirements under the General Data Protection Regulation (EU) 2016/679 or the California Privacy
Rights Act of 2020), you may not use the services provided by the Company, the Application or the Website
except
with the explicit written permission of the Company to that effect.
Personal
Information
We, on the Application/ Website, also collect and store personal
information provided by you
(“Information”), including but not limited to your
:LocationCollect and monitor
information about the location of your device to provide serviceability of your loan application, reduce
risks
associated with your application and also provide customised offers.ContactsCollect and monitor contacts and
accounts information to detect references and accounts information to autofill data during processing your
requests for value added services.Financial SMSCollect and monitor only transactional SMS (sent by 6-digit
alphanumeric senders) about bank transactions, the names of the transacting parties, a description of the
transactions etc. to help us perform a credit risk assessment. No personal SMS is stored and
collected.CameraFor
a better user experience in submitting documents.OthersAs may be explicitly required & requested from
time
to time. When you engage in certain activities on the Application/ Website, such as creating an account,
ordering a product or service, posting a review, requesting information about our services or the services
of
our partners, we may ask you to provide certain information about yourself.When you use our Website or our
Application, we collect and store your Information which is provided by you from time to time by
explicitly seeking permissions from YOU to get the required information. Our primary goal
in
doing so is to provide you a safe, efficient, smooth and customized experience and 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. More importantly, we collect Information from you
that we
consider necessary for achieving the aforementioned purpose.To the extent possible, we provide you the
option of
not divulging any specific Information that you wish for us not to collect, store or use. You may also
choose
not to use a particular service or feature of the Application/Website, and opt out of any non-essential
communications from the Company. Depending on the activity, some of the Information we ask you to provide is
identified as mandatory and some is identified as voluntary. If you do not provide the mandatory Information
for
a particular activity that requires it, you will not be permitted to engage in that activity.We only collect
and
use such Information from you that we consider necessary for achieving a seamless, efficient and safe
experience, customized to your needs and use the Information to provide products to you, enhance the
operation
of the Application/ Website, improve our marketing and promotional efforts, analyse Application/ Website
use,
improve our product offerings, to personalise your experience and to provide you a better experience.We also
collect other identifiable Information (your payment card details and transaction histories on the
Application/Website or on third parties which are linked to the Application/Website) from you when you set
up a
free account with us as further detailed below. While you can browse some sections of our
Application/Website
without being a registered member as mentioned above, certain activities (such as availing of loans from the
third party lenders on the Application/Website) requires registration and for you to provide the above
details.
The Application/Website shall clearly display the 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.DISCLOSURE TO THIRD PARTIESFurther, we may share your Information with other corporate entities,
affiliate and our partners to facilitate transactions and provide the services requested by you. Your
Information may be shared/ sold by us or our affiliates with a third party business entity in case of any
proposed merger, acquisition or re-organization, amalgamation, restructuring of business, including but not
limited to Credit bureaus financial institutions, body corporates etc. Should such a transaction occur that
other business entity (or the new combined entity) will be required to follow this Privacy Policy with
respect
to your Information.
Non-personally identifiable
information
Non-personally identifiable information is Information that does not
identify a specific end user.
This type of information may include things like the URL of the website you visited before coming to our
Website, the URL of the website you visit after leaving our Website, the type of browser you are using and
your
Internet Protocol address etc. Such Information maybe used by us or our partners to analyse trends and
gather
demographic information etc.
Where any service requested by you involves a third party, such
Information as is reasonably necessary by the Company to carry out your service request may be shared with
such
third party. We may also engage with other companies/ persons to perform functions such as order fulfilment,
delivering packages, analyzing data, providing marketing assistance, providing search results and links
(including paid listings and links), processing credit card payments, and providing customer service. They
have
access to personal Information needed to perform their functions.
We also do use your contact
information to send you offers based on your interests and prior activity. The Company may also use contact
information internally to direct its efforts for product improvement, to contact you as a survey respondent,
to
notify you if you win any contest; and to send you promotional materials from its contest sponsors or
advertisers.
Further, upon registering on the Application/Website, you may from time to time
choose
to provide payment related financial information (credit card, debit card, bank account details, billing
address
etc.). We are committed to keeping all such sensitive data/information safe at all times and ensure that
such
data/information is only transacted over secure sites of approved payment gateways which are digitally
encrypted, and provide the highest possible degree of care available under the technology presently in
use.
The
Company will not use your financial information for any purpose other than to complete a transaction with
you.
The Application and Website has reasonable security measures, including as mentioned in
Information Technology Act, 2000 in place to protect the loss or misuse of the information under our
control.
Whenever you change or access your account information, we offer the use of a secure server. However,
transacting over the internet has inherent risks which can only be avoided by you following security
practices
yourself, such as not revealing account/login related information to any other person and informing our
customer
care team about any suspicious activity or where your account has/may have been compromised.
If
you
send us personal correspondence, such as emails or letters, or if other users or third parties send us
correspondence about your activities on the Application/Website, we may collect such information into a file
specific to you.We do not retain any information collected for any longer than is reasonably considered
necessary by us, or such period as may be required by applicable laws. The Company may be required to
disclose
any information that is lawfully sought from it by a judicial or other competent body pursuant to applicable
laws.
COLLECTION OF INSTALLED APPLICATIONS
We collect a list of the
installed applications’ metadata information which includes the application name, package name, installed
time,
updated time, version name and version code of each installed application on your device to assess your
credit
worthiness and enrich your profile with pre-approved customized loan
offers.
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.
LINK TO OTHER SITES
The Application/Website may contain
links to third party websites that may collect personally
identifiable information about you. We are not responsible for the privacy practices of such websites which
we
do not manage and control.
LINK TO THIRD-PARTY SDK
Our application
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.
SECURITY PRECAUTIONS
The
Website/Application 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.
The
Website/Application 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.
YOUR CONSENT
By using the Website/Application
and/
or by providing your information, you consent to the collection and use of the information you disclose on
the
Website 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.
CHOICES AVAILABLE REGARDING
COLLECTION, USE AND DISTRIBUTION OF INFORMATION
To protect against the loss, misuse
and alteration of the information under its control, the Company has in
place appropriate physical, electronic and managerial procedures. For example, the Company servers are
accessible only to authorized personnel and your information is shared with employees and authorized
personnel
on a need to know basis to complete the transaction and to provide the services requested by
you.
Although
the Company endeavours to safeguard the confidentiality of your personally identifiable information,
transmissions made by means of the Internet cannot be made absolutely secure. By using the
Application/Website,
you agree that the Company will have no liability for disclosure of your information due to errors in
transmission and/or unauthorized acts of third parties.
Please note that we will not ask you to
share
any sensitive data or information via email or telephone. If you receive any such request by email or
telephone,
please do not respond/divulge any sensitive data or information and forward the information relating to the
same
to legal@12club.in for necessary action.
COMMUNICATION WITH
COMPANY
If you wish to correct or update any information you have provided, you may
do so online, on the Application
/Website itself. Alternatively, you may contact the Company to correct or update such information by sending
an
e-mail to: legal@12club.in
In the event of loss of access to the Application/Website, you may
contact
the Company by sending an e-mail to: legal@12club.in
In the event you wish to report a breach of
the
Privacy Policy, you may contact the designated Grievance Officer of the Company at:
Name: Mallika
Janardhan
Address: - 7th and 12th Floor, Building No. 8 Block-C, Cyber City DLF City Phase 2 Road, DLF City
Phase 2, Gurugram, Gurugram, Haryana, 122008
Email:
support@twelve.club
[9:30 AM to 6:30 PM, Monday to Friday except Public
Holidays]