Privacy Policy

FLOCRED Private Limited (CIN: U67100DL2022PTC400764) ("FLOCRED", "Company", "we", "us", or "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website flocred.com, use our mobile application, or interact with our services.

This policy is published in compliance with the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and the Digital Personal Data Protection Act, 2023 (DPDPA) as applicable.

1. Information We Collect

1.1 Personal Information You Provide:

• Identity Data: Full name, date of birth, gender, PAN number, Aadhaar number (with consent), photographs
• Contact Data: Email address, phone number, residential address, pin code
• Financial Data: Income details, employment information, bank account details, existing loan information, credit score
• Application Data: Loan type preference, loan amount, tenure preference, purpose of loan
• Career Data: Resume/CV, work experience, qualifications, city, expected salary (for career applicants)
• KYC Documents: PAN card copy, Aadhaar card copy, address proof, income documents (when required by Lending Partners)

1.2 Information Collected Automatically:

• Device Data: Device type, operating system, browser type and version, screen resolution
• Usage Data: Pages visited, time spent on pages, click patterns, referral source
• Location Data: Approximate geographic location based on IP address or timezone (used for geo-detection features like currency display)
• Technical Data: IP address, cookies, session data, log files

1.3 Information from Third Parties:

• Credit Bureau Data: Credit scores and credit reports from TransUnion CIBIL, Experian, Equifax, or CRIF High Mark (with your explicit consent)
• Lending Partner Data: Application status updates, loan disbursement information
• Public Data: Information available in public databases or government records

2. How We Use Your Information

Purpose	Legal Basis
Processing your loan applications and sharing with Lending Partners	Consent / Contract performance
Providing credit score checks and monitoring	Consent
Communicating about your applications, offers, and account	Legitimate interest / Consent
Personalizing your experience and showing relevant products	Legitimate interest
Verifying your identity and preventing fraud	Legal obligation / Legitimate interest
Sending promotional offers and financial product recommendations	Consent (opt-out available)
Processing career applications	Consent / Contract performance
Improving our Platform, services, and user experience	Legitimate interest
Complying with legal and regulatory requirements	Legal obligation
Analytics and research (in anonymized/aggregated form)	Legitimate interest

3. Information Sharing and Disclosure

We may share your information with:

• Lending Partners (Banks & NBFCs): To process your loan/insurance applications. This includes personal, financial, and KYC information necessary for credit assessment.
• Credit Bureaus: To fetch your credit score and report with your consent (TransUnion CIBIL, Experian, Equifax, CRIF High Mark).
• Service Providers: Third-party vendors who assist us with hosting, analytics, communication (SMS/email/WhatsApp), payment processing, and customer support.
• Legal Authorities: When required by law, regulation, legal process, or governmental request.
• Business Transfers: In connection with a merger, acquisition, or sale of assets, your data may be transferred to the successor entity.

We do NOT sell your personal information to third parties for marketing purposes.

4. Data Security

We implement industry-standard security measures to protect your information:

• SSL/TLS encryption for all data transmission
• Encrypted storage of sensitive data (PAN numbers, financial information)
• Access controls and role-based permissions for employees
• Regular security audits and vulnerability assessments
• Secure cloud hosting with SOC 2 compliant providers (Supabase/AWS)
• PAN numbers are masked (e.g., ABCDE****F) in our databases

While we strive to protect your data, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security.

5. Data Retention

• Loan application data: Retained for 7 years from the date of application (as per RBI guidelines)
• Credit score data: Retained for the duration of your active subscription or 1 year, whichever is longer
• Account data: Retained until you request deletion, plus any legally required retention period
• Career application data: Retained for 2 years from the date of application
• Analytics data: Retained in anonymized form indefinitely

6. Cookies and Tracking Technologies

We use the following technologies:

• Essential Cookies: Required for the Platform to function (session management, security)
• Analytics Cookies: To understand how visitors use our Platform (page views, user flows)
• Functional Cookies: To remember your preferences (currency, language, geo-location)
• Local Storage: To store form data locally as a backup and improve user experience

You can control cookies through your browser settings. Disabling certain cookies may affect Platform functionality.

7. Your Rights

Under the Digital Personal Data Protection Act, 2023 (DPDPA) and other applicable laws, you have the right to:

• Access: Request a copy of the personal data we hold about you
• Correction: Request correction of inaccurate or incomplete data
• Erasure: Request deletion of your personal data (subject to legal retention requirements)
• Withdraw Consent: Withdraw previously given consent for data processing
• Portability: Request your data in a structured, commonly used format
• Opt-out: Opt out of promotional communications at any time
• Grievance: File a complaint with the Data Protection Board of India

To exercise any of these rights, email us at privacy@flocred.com or support@flocred.com. We will respond within 30 days.

8. Children's Privacy

The Platform is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If we discover that a child under 18 has provided us with personal information, we will delete it promptly.

9. Cross-Border Data Transfers

Your data may be processed and stored on servers located outside India (including cloud servers managed by Supabase, which uses AWS infrastructure). We ensure that any cross-border transfer complies with applicable Indian data protection laws and that adequate safeguards are in place.

10. Third-Party Links

Our Platform contains links to third-party websites including those of our Lending Partners, credit bureaus, and other service providers. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before sharing information.

11. Communication Preferences

By providing your phone number and email, you consent to receive:

• Transactional communications (application updates, score reports)
• Promotional communications (loan offers, new products, financial tips)
• Service communications (Platform updates, policy changes)

You can opt out of promotional communications by clicking "unsubscribe" in emails, replying "STOP" to SMS messages, or contacting us at support@flocred.com. Transactional communications cannot be opted out of while using the service.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last Updated" date. Significant changes will be notified via email or a prominent notice on the Platform. Continued use after changes constitutes acceptance.

13. Grievance Officer / Data Protection Officer

In accordance with the Information Technology Act, 2000 and the DPDPA, 2023, the details of our Grievance Officer are:

• Name: Data Protection Officer, FLOCRED Private Limited
• Email: privacy@flocred.com
• Phone: +91-9319369315
• Address: Delhi, India

If you are not satisfied with our response, you may file a complaint with the Data Protection Board of India as established under the DPDPA, 2023.

14. Contact Us

FLOCRED Private Limited
CIN: U67100DL2022PTC400764
Email: support@flocred.com | privacy@flocred.com
Phone: +91-9319369315
Website: www.flocred.com