Privacy & Policy
1. General
Setl is managed and operated by Singularia Innovations Private Limited (“Setl”, “we”, “us” or “our”), a company incorporated under the Companies Act, 1956, having its registered office at BKC, C-20, G Block, Bandra-Kurla Complex, Bandra(East), Mumbai, Maharashtra, India, 400051.
1.1
We have developed a Fintech Application called Setl having its website address at www.setl.in (“Website/Platform”) which gives User (“You”, “Your”, “User”) a one-stop platform to the underserved customers, for various credit line needs.
1.2
This privacy policy (“Privacy Policy”), together with the Terms of Use governs your use of the Platform and describes our policies and procedures on the collection, use, disclosure, processing, transfer, and storage of the information including Sensitive Personal Information and Sensitive Personal Information (defined below) provided to us by You when: (a) you use our websites including www.setl.in (“Website”), software applications or mobile applications including the Setl application hosted on www.setl.in which is owned by us (“Apps”) or platform(s) of any of our partners (“Platforms”), or (b) you avail any products or services which we may operate or offer to you either directly through our Websites or Apps or Platforms or through a merchant or partner platform; including the steps we take to protect your Personal Information and Sensitive Personal Information.
1.3
The term Websites includes all pages that are sub-domains or are associated with or exist within each Website which are hosted by Setl. By accessing the Websites, Apps, Platforms and/or using products or services provided by Setl directly or indirectly, you agree that you have read and understood, and agree to be bound by this Privacy Policy.
1.4
By using the Websites, Apps, Platforms, and/or having used the products or services offered by Setl directly or indirectly, in the past, present or future, you expressly consent to our collection, use, storage, processing, sharing and disclosure of your Personal Information and Sensitive Personal Information submitted to us in accordance with this Privacy Policy.
1.5
You further acknowledge and accept that your consent herein shall also be applicable to your Personal Information and Sensitive Personal Information submitted to us, directly or indirectly, in the past. It is strongly recommended for you to return to this page periodically to review the most current version of this Privacy Policy which is amended by us from time to time.
1.6
Capitalised terms used herein if not defined shall have the same meaning as ascribed to them under the Terms.
1.7
This document is an electronic record and is governed by the provisions under the Information Technology Act, 2000 and rules made thereunder as may be applicable, and the amended provisions pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signatures.
1.8
This Privacy Policy sets out the type of information collected from the Users, including the nature of the Sensitive Personal Data or Information (defined hereinafter), the purpose, means and modes of usage of such information and how and to whom we shall disclose or transfer such information. You may at any time, withdraw your consent, for collection and use of your information, including Personal Information (defined hereinafter) or Sensitive Personal Data or Information. However, please note that if you withdraw your consent, we may no longer be able to provide you with the corresponding service for which you have withdrawn your consent. It is hereby clarified that your decision to withdraw your consent will not affect the processing of Personal Information based on your previous consent prior to the withdrawal.
1.9
Your privacy is extremely important to us. At Setl, we believe in being absolutely transparent about our Privacy Policy so that you can focus on availing the Services provided by the Platform without worrying. We maintain complete confidentiality of all your Personal Information and Sensitive Personal Information collected by us, on our Platform.
1.10
Please take a moment to familiarize yourself with our Privacy Policy. If you do not agree with any provisions of the Terms or this Privacy Policy, we advise you to not use or access the Platform.
1.10
This Privacy Policy applies to all current and former users accessing or using Our Platform, or otherwise engaging with us through email or other means.
1.10
Some of the information that we require you to provide on first accessing or registering on the Platform is mandatory and essential to the provision of our services to you, and hence if you do not provide such mandatory information, you may not be able to access some of the core features of the Platform.
2. What is Personal Information and what types of Personal Information do we collect about You?
2.1
“Personal information” means any information that relates to an individual, which directly or indirectly, in combination with other information available or likely to be available with us, is capable of identifying such individual.
2.2
Information freely available or accessible in public domain is not treated as Sensitive Personal Information. Depending on who you are (e.g a merchant, customer, cardholder, consumer, supplier or business partner) and how you interact with us (e.g through Website, Platform, App, telephone, IVR, API, online or offline), we may collect, use, receive, store, analyze, combine, transfer or otherwise process different categories of your Personal Information (including Sensitive Personal Information). Below is a table of the categories of Personal Information and Sensitive Personal Information which we may collect about you:
3. How is your Personal Information Collected?
3.1
You may be asked to provide your information anytime you visit, access, use or browse the Platform. We may share information and use it consistent with the provisions of this Privacy Policy. We may also combine it with other information to provide and improve our Services, content and advertising.
3.2
You agree to provide information, which shall be true, correct, up to date and accurate. You may access, amend, alter or require deletion of your information partially or fully by contacting us at Customer care ID: support@setl.in
3.3
Platform is not directed towards minors. We do not, knowingly, collect Personal Information from any User who is under 18 (Eighteen) years. If we are made aware that we have collected the Personal Information of a person below the age of 18 (Eighteen) years, we will take steps to delete the information within a reasonable time frame. If a parent or guardian becomes aware that his or her child has provided his/ her information on the Platform without their consent, he or she shall contact us for the deletion of such information. In the event, where in contravention to the Privacy Policy and Terms, a person below the age of 18 (Eighteen) years uses the services, we shall not be held liable or responsible for any damage or injury suffered by such person.
3.4
We collect Personal Information (including Sensitive Personal Information) directly from you in different ways on the Websites, Apps, Platforms or product or service offerings. For example, you give us your Personal Information (including Sensitive Personal Information) when you:
give us your Contact Information so that we can contact you about our services and products;
conclude a contract or verify to us who you are (whether by email, phone or electronic verification);
provide your Personal Information (including Sensitive Personal Information) on the Apps, Websites, Platforms or the checkout pages in order to register for availing our services or for completing a transaction(s);
apply for our products or services directly with us or through our business partners (such as various third party websites, resellers or credit providers);
directly register with us for availing any products or services including initiating an account-based relationship with us;
are prompted to give us your Identity and Account Log- In Information, Contact Information, Financial Information, Identification Information, Credit Related Information and/or Payment Information on our App, Website or web-checkout /payment pages or via other similar channels to register or complete a transaction;
give us your Credit and Lending Information to avail any loans or services directly from us, or from our business partners and third party service providers;
enter a competition, promotion or survey or you consent to be provided with marketing materials to be sent to you;
send us a support request for any of our products or services through one or more of our support desks; or
access, use and/or browse our Website(s), Apps or Platforms;
give us permission to collect the same from your device and other sources available through various means including cookies.
3.5
We obtain Personal Information (including Sensitive Personal Information) through third parties including our business partners, Singularia Innovations Private Limited Entities & Affiliates, independent service providers and third parties or from publicly available sources, if publicly available, as permitted under applicable laws of India, including:
from various merchants, marketplaces, re-sellers, banks, payment partners, payment aggregators, payments systems, payment service providers and financial institutions. For example, a merchant can share your Personal Information with us for the purpose of doing an eligibility check for our services. We encourage you to read such third parties’ privacy statements to learn more on how they process your personal information.
from group entities or independent third parties for other activities. For example, we may receive information as may be required for our internal analysis, credit checks etc. from Singularia Innovations Private Limited Entities & Affiliates for providing services to you. We may also receive your information from various third parties in the process of providing services to such third parties;
from financial institutions, and fraud prevention agencies for the purposes of conducting fraud and risk assessments or analysis. For example, before we provide or enable the provision of any services, goods or finances to you (as applicable), we may undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to collect information about you from our business partners and independent service providers including technology providers who have entered into contracts with us;
from third party service providers or technology providers, including service providers engaged in the business of collecting data from publicly available sources, who have entered into contracts with us to assist us with our business operations;
from third parties such as merchants or e-commerce platforms who have either entered into a contract with you or have obtained your consent or through any other legal means as may be available in accordance with applicable laws of India, to share your information with other parties;
from publicly available sources in accordance with applicable laws of India;
4. What are the lawful grounds that we rely on to process your Sensitive Personal Information?
We process Sensitive Personal Information only when we have obtained your consent in manner provided hereinunder. For collecting, processing (including using, processing and storing), disclosing or sharing your Sensitive Personal Information as described in this Privacy Policy, we hereby through this Privacy Policy, seek your consent and give you a notice regarding collecting, processing (including using and storing), sharing and disclosing your Sensitive Personal Information for one or more of the purposes detailed herein. For any purposes, where, as per applicable laws of India, a specific consent is required, we will seek such specific consent from you from time to time. In relation to information obtained from third parties or group entities (such as Singularia Innovations Private Limited Entities & Affiliates), we rely on the consent taken by these parties on their respective platforms in our favour for us to process the information. You may, of course, decline to share certain information with us, in which case we may not be able to provide to you some or all of the features and functionalities of the Websites, Apps and the Platform. This may also affect our ability to process your Personal Information (including Sensitive Personal Information) and may therefore lead to the non-availability or discontinuation of the services for which such Personal Information (including Sensitive Personal Information) are to be used or was being used, at our sole discretion.
5. What are the lawful grounds that we rely on to process your Sensitive Personal Information?
5.1
We may collect, use or process your information including Personal Information and Sensitive Personal Data or Information for the following purposes:
To verify, authenticate and authorize your use of our products & services
For creating and giving you access to your registered account on the Platform.
To process the transactions
To develop, deliver, process and improve our Products, services, content in order to personalize and improve your experience.
To inform you about our Products, services, offers, updates, upcoming events, as well as of our Business Partners, including providing you information in relation to order confirmations, invoices, technical notices, security alerts.
For internal analytical and research purposes such as auditing, data analysis and research to improve Our Products, Services and customer communications.
To generate variables, affluence & reliability scores.
To meet any legal or regulatory requirement or comply with a request from any governmental or judicial authority.
To resolve any request, dispute, grievance or complaint raised by you in relation to your use of the Platform.
6. Disclosure & Storage of Information Collected
6.1
We may from time to time be required to disclose the information collected from you to our trusted third party service providers who assist us in order to facilitate the provision of services on the Platform. For instance, we may share your information with a third party payment gateway provider to process transactions on the Platform. By using the Platform, you consent to any such disclosure of your information with third party service providers. We ensure that such third party service providers are bound by reasonable confidentiality obligations and/ or use, maintain and follow generally accepted industry and security standards with respect to such information.
6.2
We may also disclose your information when such disclosure is requisitioned under any law or judicial decree or when we, in our sole discretion, deem it necessary in order to protect our rights or the rights of other Users, to prevent harm to persons or property, to fight fraud and credit risk.
6.3
We may from time to time be required to disclose the information collected from you to our trusted third business partners, merchants and financial institutions who assist us in order to facilitate the provision of services on the Platform. We may also share your Personal Information (including Sensitive Personal Information) with such third parties and financial institutions to assist them in understanding your interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions and such third parties and financial institutions may market and offer their products and services to you based on this.
6.4
We may also disclose or transfer your information to any third party as a part of reorganization or a sale of the assets, division or transfer of a part or whole of us. We shall ensure that third party to which we transfer or sell our assets will have appropriate confidentiality and security measures, at least as protective as those described in this Privacy Policy, to handle your Personal Information. You will have the opportunity to opt out of any such transfer if the new entity's planned processing of your information differs materially from that set forth in this Privacy Policy.
6.5
A third party payment gateway provider may be required to collect certain financial information from you including, but not restricted to, your credit/debit card number or your bank account details (collectively referred to as “Financial Information”). All Financial Information collected from you by such third party payment gateway providers will be used only for billing and payment processes. The Financial Information collected from you is transacted through secure digital platforms of approved payment gateways which are under encryption, thereby complying with reasonably expected technology standards. The verification of the Financial Information shall be accomplished only by you through a process of authentication in which we shall have no role to play and hence, we shall bear no liability in relation to the same. We shall neither be liable nor responsible for any actions or inactions of third party payment gateway providers or any breach of conditions, representations and warranties given by them. We shall also not be obligated to mediate or resolve any dispute or disagreement between you and such third party payment service providers.
6.6
While we take best efforts to ensure that your information including Personal Information, Financial Information and Sensitive Personal Information or Data is duly protected by undertaking security measures prescribed under applicable laws, you are strongly advised to exercise reasonable discretion while providing Personal Information or Financial Information while using the services given that the Internet is susceptible to security breaches.
6.7
Your Personal Information and Sensitive Personal Information may be processed either locally in India, or in any other country where our approved third-party service providers operate, worldwide, as permitted by applicable laws, provided that all payments-related data for domestic transactions will be stored in India. Through this Privacy Policy, we hereby seek your consent to transfer your Personal Information (including Sensitive Personal Information) to our approved Singularia Innovations Private Limited Entities & Affiliates and third party service providers under designated contracts for the purposes defined under this Privacy Policy or as may be communicated to you from time to time. Should your Personal Information (including Sensitive Personal Information) move outside India, we will ensure to comply with the provisions of applicable laws and will also ensure that Singularia Innovations Private Limited Entities & Affiliates or our third party processors shall also comply with the same level of data protection as are applicable in India under applicable laws.
6.8
We reserve the right to conduct a security review at any time to validate your identity, age, the state from where you are accessing the Platform and other registration data provided by you and to verify your use of the services and your financial transactions for potential breach of our Terms of Use and of the applicable law. By using our Platform, you authorize us, our staff, agents to use your Personal Information and to disclose your Personal Information to third parties for the purposes of validating the information you provide to us.
7. Security
7.1
The security of your Personal Information is important to us. We have implemented security policies, rules and technical measures, as required under applicable law including firewalls, transport layer security and other physical and electronic security measures to protect the Personal Information that it has under its control from unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss. When you submit your information on the Platform, your information is protected through our security systems. Please note that we use international and industry-recognized standards such as per applicable laws, rules and regulations.
7.2
Your information is contained within secured networks and is only accessible by a limited number of authorized persons who have access rights to such systems or otherwise require such information for the purposes provided in this Privacy Policy. These authorized persons are also under an obligation to keep such information confidential.
7.3
Although we make best possible efforts to transmit and store all the information provided by you in a secure operating environment that is not open to the public, you understand and acknowledge that there is no such thing as complete security and we do not guarantee that there will be no unintended disclosures of any information and potential security breaches. You agree not to hold us responsible for any breach of security or for any action of any third parties that receive your Personal Information or events that are beyond our reasonable control including, acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, etc.
7.4
We have put in place procedures to deal with breach of Personal Information and will notify you and any applicable regulator or authority of a breach where we are legally required to do so.
8. Cookies Policy
8.1
Due to the communications standards on the Internet, when you visit, access or browse the Platform, we automatically receive the uniform resource locator of the site from which such you visit, access or browse the Platform, details of the website you visit on leaving the Platform, the internet protocol (“IP”) address of each User’s computer/mobile operating system, type of web browser the User is using, email patterns, and the name of the User’s internet service provider. This information is used solely to analyse overall User trends and to help us improve our services. Please note that the link between the User’s IP address and the User’s personally identifiable information is not shared with third parties without such User’s permission or except when required by law or to provide or facilitate the User with the services. Notwithstanding the above, the User acknowledges that we reserve the right to share some of the aggregate findings, including the personal information provided by the Users in an unidentifiable, aggregate form, and not the specific data with advertisers, sponsors, investors, strategic partners, and others in order to help grow the business. The amount of information sent to us depends on the settings of the web browser used by the User to access the Platforms. The User may refer to the browser used, if the User wishes to learn what information is provided to us.
8.2
The Platform uses temporary cookies to store certain data. We do not store Personal Information in the cookies. Information collected by us, by any means whatsoever, that does not personally identify the User as an individual (such as patterns of utilization described above) is exclusively owned by us and may be used by us and third party service providers for technical administration of the Platforms, user administration, research, development, and other purposes.
8.3
You understand that you may set or amend your web browsers to delete or disable cookies. If you choose to disable cookies on your computer or mobile telecommunication device, it may impair, degrade or restrict access to certain areas of the Platform.
8.4
We may allow our business partners, Singularia Innovations Private Limited Entities & Affiliates, and other third party service providers to serve advertisements to you. These companies or entities include third party advertisement servers, advertisement agencies, advertisement technology vendors and research firms. We may target some advertisements to you that fit a certain general profile. We do not use Personal Information to target advertisements to you. In the course of serving advertisements or optimizing the services to its Users, we may allow authorised third parties to place or recognize a unique cookie on the User’s browser.
8.5
You agree and understand that we do not exercise control over third party websites displayed as search results or links on the Platform. These other sites may place their own cookies or other files on the Users’ computer, collect data or solicit personal information from the Users, on which we have no control and shall not be held responsible or liable. We do not make any representations concerning the privacy practices or policies of such third parties or terms of use of such websites, nor do we guarantee the accuracy, integrity, or quality of the information, data, text, software, sound, photographs, graphics, videos, messages or other materials available on such websites. The inclusion or exclusion does not imply any endorsement by us of such websites, the websites’ provider, or the information on the website.
8.6
We may keep records of telephone calls received from and made to Users for the purpose of administration of services, research and development, training, business intelligence, business development, or for User administration. We may share such telephone records with third parties when required by law or when required to provide or facilitate the User with the services.
8.7
You consent to our reproduction/publishing of all testimonials and reviews given by you on the Platform in relation to the services or the Products. You agree that we may edit the testimonials and reviews provided by you and reproduce/publish such edited or paraphrased versions of the testimonials and reviews on the Platform. If the User has any concerns with the reproduction/publication of any testimonial or review provided by you, the User may contact us at Customer care ID: support@setl.in
9. Marketing
In relation to the products and services provided by us or Singularia Innovations Private Limited Entities & Affiliates or by third parties with whom we share your Personal Information and Sensitive Personal Information as per this Privacy Policy, you may receive marketing communications from Setl or such other Singularia Innovations Private Limited Entities & Affiliates or third parties, by messages, or email or through other digital modes, on Platforms, Websites and Apps or such other platforms including social media platforms, or on such third party platforms Websites and Apps including social media platforms, if you have provided us your Personal Information or Sensitive Personal Information. We may market our own products or services including the products and services offered by Singularia Innovations Private Limited Entities & Affiliates and the product and services being offered by third parties using such communication. The provision of such marketing activities shall be in accordance with applicable laws. For the marketing activities done by us, we execute contracts with our merchants, service providers, banks, Singularia Innovations Private Limited Entities & Affiliates or other third parties. You are entitled to opt out from receiving such marketing communication by either clicking on opt-out link (if available) or un-subscribe by clicking the link provided (if available) or by writing to us at support@setl.in
We may also use Marketing and Communications Information in order to improve and customize the content of our ads, promotions and advertising that may be of interest to you.
10. Opt-Out Policy
10.1
We provide you with the opportunity to opt-out of receiving non-essential, promotional, or marketing-related communication from us or Singularia Innovations Private Limited Entities & Affiliates, our business partners & other third party service providers.
10.2
If you wish to remove your contact information from all our mailing lists and newsletters, you can click on the "unsubscribe" link or follow the instructions in each e-mail message. Alternatively, you can contact us at Customer care ID support@setl.co
.in
11. Retention of information
We may store your Personal Information and Sensitive Personal Information for as long as the same is required for the fulfilment of purposes for which we collected it. The retention of Personal Information and Sensitive Personal Information by us is determined by considering compliance with legal (contractual, statutory or regulatory requirements), accounting and compliance reporting requirements under the applicable law.
12. Third Party Platforms & Services
The Platform may contain links to third-party websites or services (“External Resource”). Your browsing on and interaction with any External Resource, irrespective of whether the link to such External Resource originated on our Platform, is subject to the terms and privacy policies of such External Resource. We are not responsible for the functionality, privacy, or security measures of any other entity and this Privacy Policy will not govern your use and access of such website or service you are redirected to.
13. Modification
We reserve the right to amend this Privacy Policy at any time. The Privacy Policy, as and when modified, shall be updated on the Platform. We encourage you to review this Privacy Policy whenever you visit our Platform to understand how your Personal Information is used.
14. Governing Law
The terms of this Privacy Policy shall be governed and construed in accordance with the laws of India. Any dispute regarding or arising out of this Privacy Policy shall be subject to the exclusive jurisdiction of the courts in Mumbai, Maharashtra.
15. Severability
Whenever possible, each section of this Privacy Policy shall be interpreted in a manner so as to be valid under applicable law. However, in the event any provision is held to be prohibited or invalid, such provision shall be ineffective only to the extent of such prohibition or invalidity, without invalidating the remainder of such provision or other remaining provisions of this Privacy Policy.
16. Feedback or Concern
If the User has any concerns, feedback, review or any request, the User is free to contact the Company at Customer care ID: support@setl.in
Company Details: Singularia Innovations Private Limited
BKC, C-20, G Block, Bandra-Kurla Complex,
Bandra(East), Mumbai,
Maharashtra, India, 400051
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