Introduction
1. FPL Consumer Services Private Limited (“FPL CS”) is committed to
safeguarding the privacy and confidentiality of your data or information.
2. In the process of an user (“you”, “your”, “user”) using this website i.e.,
https://www.onescore.app/ (“Website”) and/or the app ‘OneScore’ (“App”) or
availing of the existing or future services or facility provided by the
Website and/or the App, you may be required to furnish information, including
personal information and/or sensitive personal information and/or any other
information that is of a confidential nature. You are urged to keep the
information current to ensure that the services and facility remain relevant
and enable us to reach you.
Section A - General Privacy Policy
1. This section A is the general privacy policy (“Privacy Policy”) that is applicable to all
users who avail any services or products provided by FPL CS on the
App/Website.
2. Information supplied by you: To avail certain services on our
App/Website, you are required to provide personally identifiable information /
personal data for the registration process, which includes but is not limited
to the following:
i. Name;
ii. Mobile number;
iii. Gender;
iv. Email address;
v. Permanent Account Number (PAN);
vi. Date of birth;
vii. Address.
3. Subject to the terms of this Privacy Policy, (i) FPL CS may require you to
provide additional details, as and when required, in order to comply with any
applicable regulatory requirement or for additional services/products via the
App/Website, as and when offered; and (ii) FPL CS may also utilize data
lawfully obtained from third party service providers authorized by you, to
provide the App services/Website services. We also maintain some records of
users (including recordings of customer support calls) who contact us for
support, for the purpose of responding to queries or other related activities.
4. Express Consent
i. While providing your details/documents via the
App/Website, including but not limited to personal information as mentioned
above, you consent to FPL CS (including its marketing channels and business
partners) to contact you through SMS, WhatsApp, push notifications, call and/
or e-mail and to follow up calls in relation to the services provided through
the App/Website, for imparting product knowledge, offering promotional offers
running on the App/Website & various other offers offered by our business
partners. The App/Website requires you to provide consent for keying in or
uploading your personal information, as may be necessary to process your
application. Any personal information which requires to be keyed in or
uploaded is required for enabling hassle free, faster and paperless (to the
extent possible) processing of applications for financial products so opted/
availed by you.
In order to expand the scope of our services, we may from time
to time, seek additional information from you. Any such collection of
additional information and documents shall be subject to an explicit & purpose
specific consent sought from all users.
5. Information obtained from Credit
Information Companies on your behalf We obtain your credit information reports
from credit information companies registered under the Credit Information
Companies (Regulation) Act, 2005 (“CICs”) on your behalf. By consenting to use
and avail your credit information report through us, you agree that FPL CS
shall be entitled to rely on your authorisation and consent granted by you to
us, and authorised to share your personal information with CICs. We may
analyse and profile your credit report in order to assist you in being better
informed, understand and manage your credit score/rating, and to identify
whether you may benefit from additional guidance concerning your credit score
and steps you can take to improve your score and credit history etc. We may
process these credit reports to derive credit information aggregates and then
share these credit information aggregates with our partner regulated entities
(“RE”) to assess and evaluate your application in order to provide financial
products, such as credit cards, personal loans etc., as requested / required
by you.
6. Information automatically collected while using the app or website
We strive to keep automatically tracked information to a minimum by obtaining
little or no permissions from the App/Website. However, we may collect
information relating to your use of our App such as your IP address, browser
type, mobile operating system, manufacturer and model of your mobile device,
access time and time spent. We may also collect information about the screens
you view within our App and other actions you take while using our App. We may
use third party services for such automatic collection, however no personally
identifiable information will be shared with such third parties, unless
required under applicable laws.
7. Use of personal information
i. Information collected using App / Website is used for specific business purposes or for a
lawful purpose to comply with the applicable laws and regulatory contractual
obligations which include, but are not limited to:
a. Personalise your experience whilst you are on App / Website
b. Customise our interactions with
you and assisting in expanding the scope of our services,
c. Verifying your
identity for the purposes of providing banking or non-banking services,
d.
Providing you with financial products,
e. Create and maintain a trusted and
safe environment on App / Website (such as complying with our legal
obligations and compliance with our policies),
f. Analytics for the purposes
providing you with personalized offers and improving our products and
services,
g. Assessing and processing applications or requests from you,
h.
Communicating with you through various channels,
i. Notifying you about
changes to our services,
j. Responding to your queries submitted by you
through various channels,
k. Addressing and / or investigating any complaints,
claims or disputes,
l. Conducting credit checks, screenings or due diligence
checks as may be required under contractual arrangement with partner bank or /
and non-banking financial company,
m. Preventing crime including fraud and
financial crime,
n. Financial reporting through partner REs, audit and record
keeping purposes,
o. Facilitating KYC services to the partner REs in order to
expedite the onboarding process or related processes,
p. For any other purpose
with your consent.
ii. Any information provided by you will be used for
creating and updating your account and for providing you products and services
or for any other purposes for which you have granted access to such
information to us, based on your interaction with the App/Website.
iii. We may
also use the information collected to perform internal operations necessary to
provide our services, including to troubleshoot software bugs and operational
problems, to conduct data analysis, testing and research and to monitor and
analyse usage and activity trends. We process this personal information for
these purposes given our legitimate interest in improving the services.
8.
Information Sharing
i. We may share your information with the following
entities, in order to provide you the services, or as may be required by
applicable law, or help us operate our business:
a. FPL CS’s affiliates,
b.
partner REs and service providers (e.g. collection agencies,
telecommunication, electronic clearing network).
ii. Subject to prior explicit
consent from you, we may share your information with credit information
companies (e.g. Experian Credit Information Company of India Private Limited,
TransUnion CIBIL Limited).
iii. For the sake of clarity, we do not sell or
lease such information.
iv. We may advertise our services on other
websites/apps. We may collaborate with other website/app operators as well as
network advertisers to do so. We request you to read and understand such
concerned third party privacy policies to understand their practices relating
to advertising, including what type of information they may collect about your
internet usage. No personally identifiable information is shared with any
third party online advertiser, website or app as part of any such activity. We
do not provide any information relating to your usage on App/Website to such
website operators or network advertisers.
v. During your use of the
App/Website, you may come across links to third party websites/apps that are
not affiliated with FPL CS. FPL CS is not responsible for the privacy
practices or the content of those other websites, or for any acts/ omissions
by such third parties in the course of your transaction/interaction with them.
vi. We may share your personal information with governmental authority/agency,
regulator, court/tribunal proceedings if required by applicable law or by any
court or governmental agency or authority to disclose, for the purpose of
verification of identity, or for the prevention, detection, investigation
including cyber incidents, or for prosecution and punishment of offences.
9.
Information Security
i. Your information is subject to rigorous security
protocols for storage, handling, and access. We take appropriate security
measures to protect against unauthorised access. These include internal
reviews of our data collection, storage and processing practices and security
measures, including appropriate encryption and physical security measures to
guard against unauthorised access to systems where we store personal data. All
information gathered on our App/Website is securely stored within a controlled
database within servers and data centres located in the geographical territory
of India. Access to the servers is password-protected and is strictly limited.
ii. We are ISO/IEC 27001 compliant company which means we have implemented
applicable industry standard security controls that help us protect our
customer’s data in a secure manner. You may be assured that in case we become
aware of any security breach of your data, we shall take all measures in line
with the aforementioned standards.
iii. We are committed to our customer's
data and privacy. We blend security at multiple steps within our products with
state of the art technology to ensure our systems maintain strong security
measures. The overall data and privacy security design allows us to defend our
systemsranging from low hanging issues up to sophisticated attacks. In the
unfortunate event of any unauthorized access or breach, we will act promptly
to restore your data, work with law enforcement if necessary, and reinforce
our defenses to ensure it does not happen again.
10. Opt-Out Please refer to
our consent withdrawal policy at
https://www.onescore.app/consentwithdrawalpolicy/
for withdrawing your consent
to use or process your personal information.
11. Data Retention & Data
Deletion
i. We will retain your information for the following events: (i) for
as long as it is necessary to provide you the services available on the App or
Website, (ii) your request for termination of your account with us, (iii) your
explicit withdrawal of consent, or (iv) request for deletion of your personal
information, whichever is later. We will delete your information as per our
organization level protocols / policies / processes and in accordance with
applicable law. We retain the trail of such deletion process.
ii. Post
termination of your account, we may continue to use your anonymised data
aggregated or in combination with anonymised data of other users. We use this
aggregated anonymised data for data analysis, profiling and research purposes.
In certain circumstances, we may be unable to delete your account, such as if
there is any outstanding dispute, or unresolved claims pending on your
account. However, upon resolution of the issue preventing deletion, the
information is immediately deleted and can’t be recovered thereafter. We may
keep your contact information along with your application details (if any) for
fraud prevention purposes and for the exercise/ defence of a legal claim or
for providing evidence in legal proceeding(s) to fulfil our legal and
contractual obligations and compliance requirements.
12. Log Files This
information may include internet protocol (IP) addresses, browser type,
internet service provider (ISP), referring/exit pages, operating system,
date/time stamp, and/or clickstream data. We may use the collected log
information about you to improve services offered to you, to improve
marketing, analytics, or App/ Website functionality.
13. Confidentiality of
your account User is solely responsible for maintaining the security of
his/her account and must not provide these credentials to any third party. If
you believe that they have been stolen or been made known to others, you must
contact us immediately at onescorehelp@onescore.app. We are not responsible if
someone else accesses your account through the login credentials they have
obtained from you or through a violation by you of this Privacy Policy.
14.
Grievance Redressal Policy If you have any grievance, complaint, questions,
comments, concerns or feedback in relation to the processing of information or
regarding this Privacy Policy please refer to our grievance redressal policy at
https://www.onescore.app/grievanceredressalpolicy/
.
15. Changes to this
Privacy Policy FPL CS retains the authority to modify this policy at its own
discretion. We may revise this Privacy Policy to account for alterations in
legislation, our data collection and usage practices, the functionalities of
our services, or technological advancements. We encourage you to periodically
review this page for the latest information on our privacy practices.
Section B. Privacy Policy Specific to Personal Loan in App
1. This section B is in
addition to the general Privacy Policy as specified in Section A hereinabove.
This section B (read with section A) specifically applies to the users who
avail the services related to personal loan (“PL”) as provided by FPL CS on
the App.
2. The App/Website is a digital lending app (DLA) and FPL CS acts as
a lending services provider (LSP) to various banks and NBFC (Lenders) and
allows users to apply for and access PL from the Lenders. Please see
https://www.onescore.app/lendingpartners/
for the full list of lenders. Please
note that you may be subject to the privacy policies of the Lenders and the
other obligations included in the loan documents in addition to this Privacy
Policy.
3. Data collection, storage and sharing
i. In addition to the
information collected as specified in Section A, we may collect further
information for providing the PL services. We may collect the following:
a.
Mother’s name
b. Father’s name
c. Nationality;
d. Marital status;
e. Spouse’s
name;
f. Residential Status;
g. Type of current residence
(self-owned/rented/paying guest/others)
h. Employment Status (if
employed/salaried or not);
i. Occupation;
j. Employer name;
k. Employer email
ID;
l. Annual income;
m. Salary credit/deposit mode;
n. Bank account details
(bank account name, bank account number, IFSC code);
o. Selfie.
ii. We may
share your information with the following entities, in order to provide you
the services, or as may be required by applicable law, or help us operate our
business:
a. FPL Technologies Private Limited,
b. TransUnion CIBIL Limited,
c.
Experian Credit Information Company of India Private Limited.
iii. As a part
of the application process for PL, we may share the data previously provided
by you with the Lender(s). You may also have to provide additional information
as a part of the application process. Any information provided specifically
for the purpose of accessing PL or generated upon successfully receiving
credit from the Lenders, will be retained to the extent required by FPL CS to
carry out its LSP obligations as set out in its contracts with the Lender(s).
iv. In respect of the information specifically provided as a part of the
application process for PL, FPL CS and the Lender shall collectively decide
and abide by the mutual understanding arrived at on matters regarding the
storage of customer data including the type of data that can be stored, the
length of time for which data can be stored, restrictions on the use of data,
data destruction protocol, standards for handling security breach etc.
v. We
do not collect your biometrics.
vi. We will not access your mobile phone
resources such as file and media, contact list, call logs, telephony
functions, etc., in relation to the PL or as part of its role as a DLA / LSP.
However, we may, with your prior explicit consent, seek one-time access for
camera, microphone, location or any other facility necessary for the purpose
of on-boarding requirements in connection with the PL.
vii. All the data is
securely stored in servers, databases and data centres located in the
geographical territory of India.
viii. In addition to this clause vis-à-vis
data sharing, please refer to the clause pertaining to ‘Information Sharing’
as specified in Section A. In case of any contradiction (to the extent of data
sharing with respect to PL) between this clause and clause pertaining to
‘Information Sharing’ as specified in Section A, this clause shall prevail.
4.
Data deletion and revocations You may request deletion of your data in
accordance with ‘Opt-Out’ clause of Section A as set out above. Provided
however, FPL CS as LSP and the Lenders may still retain data as required under
applicable law and to the extent that any amounts are outstanding under PL or
till the time approved in-principle credit limit is available to you.
5.
Grievance Redressal Policy For PL related grievance or complaint, you can send
email to our grievance officer by accessing the lending partners page
https://www.onescore.app/lendingpartners/
. The grievance redressal officer
shall address your concerns within a month from the date of receiving the
grievance.