Gruhfin Services LLP (hereinafter referred to as “GSL/ We/ Our/Gruhfin”) acknowledges the expectations of its customers (hereinafter referred to as “customer/ you/ your”) regarding privacy, confidentiality and security of personal information that resides with the Gruhfin Services LLP. Keeping personal information of customers secure and preventing any misuse thereof, is therefore, a top priority of GSL.
We state that GSL is strongly committed to protect the privacy of its customers and has taken all necessary and reasonable measures in line with applicable laws and regulations as well as the best industry practice to protect the confidentiality of your personal information and its transmission through our website.
This Policy is published and shall be construed to be in accordance with the provisions of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data of Information) Rules, 2011 under the Information Technology Act, 2000 and other applicable laws and regulations that require publishing of the privacy notice for collection, usage, storage, disclosure and transfer of sensitive personal data or information.
Personal Information (“PI”) means any information/ documents/ details that relates to a natural person, which either directly or indirectly in combination with other information available with GSL, can identify such person.
(i) This Policy applies to the PI such as details pertaining to your name, parentage, marital status, nationality, state/city of residence, residential address, e-mail address, date of birth, gender, contact number/mobile number, user ids, passwords, recent photograph, signature image, income proof, PAN, credit score, credit information report, e-KYC through UIDAI, Aadhaar based e-Sign and such other Know Your Customer (KYC) documents like address proof, identity proof, officially valid documents/details (OVDs) accepted for concluding a financial transaction, which may be shared/ uploaded by you, as and when you avail any products or use the Website and to which Gruhfin may become privy to.
(ii) By visiting and/or using our Website, you agree to this Policy. Further, this policy applies to all current and former visitors to the Website. It is strongly recommended for you to return to this page periodically to review the most current version of the Policy.
(iii) GSL reserves the right at any time, at its sole discretion, to change or otherwise modify the Policy without prior notice, and your continued access or use of this Website signifies your acceptance of the updated or modified Policy. However, if we make any material change to the Policy, we will notify you by e-mail (sent to the e-mail address specified in your account) or by means of a notice on this Website prior to the change becoming effective.
The information we learn from customers helps us personalize and continually improve your experience at the Website.
Here are the types of information we gather:
How do We Use the Information?
Gruhfin collects your information when you register for an account, when you use its products or services, visit its website’s pages. When you register with the Website and sign in you are not anonymous to us. Also, you are asked for your contact number and other details during registration and may be sent SMS, electronic mails (“e-mails”), notifications, WhatsApp messages about our services to your wireless device.
(i) By making use of the Website, and furnishing your personal and contact details, you hereby agree that you are interested in knowing more or availing and/or purchasing various products, services, offers, campaigns or other promotional material that Gruhfin or our associate/partners or any other third party may offer/provide/share/send you from time to time through any means including but not limited to telephone, SMS (short messaging service), electronic mail (e-mail), WhatsApp or any other messaging service/mobile application or any other physical, electronic or digital means/mode . You hereby agree that Gruhfin may contact you either directly or through their associate/ partners electronically or through phone, to understand your interest in the selected products and Services and to fulfil your demand or complete your application. Further you also expressly agree and authorize GSL and its associates,partners, service providers, vendors and other third parties to contact you for the purpose of offering or inviting your interest in availing other products or services offered by third parties, or for sending other marketing campaigns, offers, or any other information either on the Website or through other means including but not limited to telephone, SMS (short messaging service), electronic mail (e-mail), WhatsApp or any other messaging service/mobile application or any other physical, electronic or digital means/mode. You agree and authorize Gruhfin to share your information with its group companies, vendors, service providers, business partners, agents and other third parties, in so far as required for marketing purposes/offering/cross-selling various other products and services and/or to provide you with various value-added services, in relation with the Services selected by you or generally otherwise. You agree to receive communications through emails, telephone, WhatsApp, SMS, or any other form of messaging/communication service from GSL or such third parties. You also agree that Gruhfin reserves the right to make your details available to its partner banks/financial institutions or any such other third party and that you may be contacted by the associate/partners and/or the third party for information through email, telephone, WhatsApp and/or SMS.
(ii) The usage of the Website may also require you to provide consent for keying in your Personal Information (“PI”) (including but not limited to any personal data or sensitive personal data as defined under applicable law) or to authorize GSL to derive your data/information from any other source or public registry, as may be necessary to complete your profile or your application on the Website, conduct due diligence on you, assessing your eligibility for the products/services, undertaking know-your-customer (“KYC”) checks by GSL or any other third party and/or to process your application through this Website. Your PI may also be used or shared with third parties including but not limited to our vendors, service providers, credit information agencies, analytics and research partners, other banks or financial institutions, insurers or intermediaries or any other third party with the intent of making your experience on the Website better, faster and paperless and frictionless to the extent possible. Gruhfin shall adhere to best industry practices including information security, data protection and privacy law while processing such applications. However, GSL shall not be liable to you against any liability or claims which may arise out of such transactions as any such PI is being collected, used, processed and shared with your explicit consent.
(iii) You hereby authorize and expressly consent us to share your PI with third parties including but not limited to Credit Information Companies (“CIC”) to do an aggregate check of your credit profile for Gruhfin to send you targeted communications and offers.
(iv) If you are no longer interested in sharing your PI, please e-mail your request at: [email protected]. Please note that it may take about 72 business hours to process your request. In furtherance to your usage of the Website, you expressly waive the Do Not Call (DNC) / Do Not Disturb (DND) registrations on your phone/mobile numbers for contacting you for such purpose and usage. Hence, there will be no DNC / DND check required for the number you may have left on our website. Such modes of contacting you may include sending SMSs and/ or telephonic calls.
(v) GSL reserves the right (and you expressly authorize (GSL) to share or disclose your PI when GSL determines, in its sole discretion, that the disclosure of such information is necessary or appropriate under the law for the time being in force.
(i) Your Credit Information (credit score and credit information report) is procured through a 'soft search' of your credit records with Credit Information Companies “CICs” and Gruhfin has no control over the content or accuracy of information provided in your credit information by CICs. Gruhfin gets this information from CIC for and on your behalf only when you agree to appoint Gruhfin as your lawfully appointed authorized agent/ representative for collecting your credit information from CICs. By consenting to use and avail your credit information report through Gruhfin, you agree that Gruhfin and CICs shall be entitled to rely on your authorization and consent granted by you to Gruhfin.
(ii) Availing your credit information through Gruhfin is subject to your passing of appropriate identity authentication for security and privacy purposes. Gruhfin shall not notify you the reasons if you are unable to pass such identity authentications and not able to view and/or use your credit information.
(iii) Gruhfin may analyse and profile your credit information in order to assist you in being better informed about, understand and manage your credit score/rating, identify and inform you of credit products that are likely to be suited to your circumstances, 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. For more details, please access Gruhfin’s Terms of service for credit information.
(i) Gruhfin collects, receives, possesses, stores, deals or handles PI received from investors/client/customers whether existing or prospective. Such PI may be as per the indicative list given below:
(ii) The aforesaid information is being collected by Gruhfin to respond to your requests, to process the investment applications and to also ensure safe subscriptions/redemptions of mutual fund investments. Gruhfin may also call you to inform them with respect to the other products or services offered by its partner AMCs. The said information is also being collected to be compliant with the Know Your Client (KYC) norms under the Prevention of Money Laundering Act, 2002 (PMLA), the rules issued thereunder, and guidelines and circular on Anti- Money Laundering issued by SEBI and SEBI (Mutual Funds) Regulations, 1996 as amended till date.
In case you do not want to be disturbed over telephonic calls, kindly fill up the details requested in the below table, including the details of the telephone number(s) on which you do not wish to be contacted and submit the same at [email protected] from your email address registered at Gruhfin. The details that you provide through the opt-out email will remain confidential and once you have submitted the same to us, your telephone number(s) will be removed from all our telemarketing calling lists within 21 working days. We will make every effort to ensure that you do not get any further telemarketing calls on such telephone number(s). The details to be submitted for opting-out shall be as below:
We may also share your information, without obtaining your prior written consent, with government agencies mandated under the law to obtain information for the purpose of verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment of offences, or where disclosure is necessary for compliance of a legal obligation. You agree and consent for the Website to disclose your information, if so required, under applicable law.
Further Gruhfin may use your information to:
(ii) In the event that you access the Service as brought to you by one of our partners either through the Website or on being redirected from a co-branded URL or any other website , your name, e-mail address, mobile number, date of birth, employment type, residency status, income details/proofs, Form 26 AS, PAN, details of loan / credit card/ mutual fund applied for and loan, credit card and mutual fund status or any other financial product status may be provided to that partner when your application is submitted and whenever the status of application is updated. Gruhfin has a business relationship with these partners and you may not opt-out of sharing your information with these partners if you have applied via a co-branded URL or any other website or directly through the Website as the case may be.
(iii) For availing the Service such as applying for credit information report, loan, credit card, mutual fund or any other financial product we will require you to provide/upload on the Website the details such as a your name, parentage, marital status, email address, nationality, location, mobile number, PAN, employment & income details/proofs, Form 26 AS, recent photograph, signature image, other Know Your Customer (KYC) documents like address proof, identity proof and personally identifying information about a potential co-loan applicant (should you select this option), and to participate on our forum boards, you must provide a username for yourself.
(iv) You may opt out of location-based services at any time by editing the setting of your browser.
(v) In order to provide your bank statement or pay slip electronically along with your loan application, you also must provide your third-party account credentials ("Account Credentials") to allow Gruhfin to retrieve your account data at those other financial institutions ("Account Information") for your use. Your Account Credentials are only used once to retrieve your bank statements/pay slips, Form 26 AS and are not stored in our system. Gruhfin shall not be liable to you against any liability or claims which may arise out of such transactions being carried on your own accord.
(vi) We may also use third party service providers to provide the Service to you, such as sending e-mail messages on our behalf or hosting and operating a feature or functionality of the Service. Our contracts with these third parties outline the appropriate use and handling of your information and prohibit them from using any of your PI for purposes unrelated to the product or service they're providing. We require such third parties to maintain the confidentiality of the information provide to them.
(i) Gruhfin does not disclose PI of a customer except as directed by law or as consent received from the customer / applicant. No specific information about customer accounts or other personally identifiable data is shared with third parties unless any one of the following conditions is met:
(ii) There are number of products/services such as loans, credit cards, mutual funds, offered by third Parties on the Website, such as lenders, banks, credit card issuers. If you choose to apply for these separate products or services, disclose information to these providers, then their use of your information is governed by their privacy policies. Gruhfin is not responsible for their privacy policies. Gruhfin may share your data with other third parties, such as service providers, advertisers, Credit Information Companies, fraud prevention agencies, marketing channels, affiliates, without the need for additional consent from you.
(i) If your PI provided to us when you had applied for a product on our website changes, you may update it whenever you apply for a new product via our website. To review and update your PI and to ensure that the same is accurate while your application is in process, you may contact us at [email protected] You will not be able to update the information you have provided in an application after a decision has already been made on it; however, you may create and submit a new application with your updated information.
(ii) Note: We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us at [email protected] We will respond to your request within a reasonable timeframe. However, we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and to enforce our agreements.
(i) Gruhfin will retain your information for as long as it is necessary for providing you the Services available on the Website or your request for termination of your account with Gruhfin, whichever is later.
(ii) Post termination of your account, Gruhfin may continue to use your anonymized data aggregated or in combination with anonymized data of other users. We use this aggregated anonymized data for data analysis, profiling and research purposes, for example to gain insights about our users and their profiles. We may keep your contact information along with your application details (if any) for fraud prevention purposes and for the exercise/defense of a legal claim or for providing evidence in legal proceeding(s).
We provide our registered customers with periodic phone calls, emailers and email/SMS/WhatsApp alerts. We also allow users to subscribe to email newsletters and from time to time may transmit emails promoting Gruhfin or third-party products. Subject to the express consent clause above, Gruhfin’s Website subscribers may opt-out of receiving our promotional emails and terminate their newsletter subscriptions by following the instructions in the emails. Opting out in this manner will not end transmission of service-related e-mails/SMS/WhatsApp, such as e-mail/SMS alerts. The above services are also provided by our partners.
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 Website functionality.
We partner with a third-party service provider to either display advertising on our website or to manage our advertising on other websites. Our third-party partner may use technologies such as cookies to gather information about your activities on this Website and other websites in order to provide you advertising based upon your browsing activities and interests.
There are several products and services, such as credit information report, loans, credit cards, mutual fund and other financial products being offered by third parties on our website, such as lenders, banks, credit card issuers and mutual funds (collectively "Offers"). If you choose to apply for these separate products or services, disclose information to the providers, or grant them permission to collect information about you, then their use of your information is governed by their privacy policies. You should evaluate the practices of these external services providers before deciding to use their services. Gruhfin is not responsible for their privacy practices.
(i) With your consent Gruhfin may post your testimonial along with your name. If you want your testimonial removed, please contact Gruhfin at [email protected].
(ii) If you use a blog, comments section or other public forum on Website, any information you submit there can be read, collected or used by other users and could be used to send you messages. Gruhfin shall not be held responsible for the PI you choose to submit in these forums.
(ii) Single Sign-On: You can log in to our website using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to share certain PI with us such as your sign-in information, name and email address to link between the sites. Social networking media services like Facebook & Twitter give you the option to post information about your activities on this Website to your profile page to share with others within your network.
(iii) Like Button: If you use the "Like" button to share something that item will appear on your Facebook profile page and on your friends’ newsfeed depending on your Facebook privacy settings. You may also receive updates in your Facebook newsfeed from this Website or item in the future. Facebook also collects information such as which pages you have visited on this and other sites that have implemented the "Like" button.
(i) We follow generally accepted standards to protect the PI submitted to us, both during transmission and once we receive it. Since no method of transmission over the Internet, or method of electronic storage, is 100% secure, therefore, we cannot guarantee its absolute security. If you have any questions about security on our website, you can contact us at [email protected].
(ii) We use a combination of firewalls, encryption techniques and authentication procedures, among others, to maintain the security of your online session and to protect Gruhfin online accounts and systems from unauthorized access.
(iii) When you register for the Service, Gruhfin requires a password from you for your privacy and security. Gruhfin transmits information such as your login credentials for Website or Account Credentials securely.
(iv) Our servers are in secure facilities where access requires multiple levels of authentication, including an identity card and biometrics recognition procedures. Security personnel monitor the facilities 7 days a week, 24 hours a day.
(v) Our databases are protected from general employee access both physically and logically. We encrypt your Service password so that your password cannot be recovered, even by us. All backup drives and tapes also are encrypted.
(vi) We enforce physical access controls to our buildings. No employee can put PI on any insecure machine (i.e., nothing can be taken from the database and put on an insecure laptop). We permit only authorized employees who are trained in the proper handling of customer information, to have access to aforesaid PI.
(vii) Gruhfin has been verified for its use of SSL encryption technologies. In addition, Gruhfin tests the Website using Acunetix scan for any failure points that would allow hacking. However, it is important to understand that these precautions apply only to our website and systems.
All communications between your computer/mobile and our website that contain any PI are encrypted. This enables client and server applications to communicate in a way that is designed to prevent eavesdropping, tampering and message forgery.
(ii) If you have any security related concern, please contact us at [email protected]. We will work closely with you to ensure a rapid and personal response to your concerns.
ISO/IEC 27001:2013 is the international standard for management of information security and provides a systematic approach to keep your PI and sensitive company information secure. Getting the ISO 27001:2013 certificate is a reassurance for our customers that Gruhfin complies with the highest standards regarding information security. Gruhfin is ISO/IEC 27001:2013 certified under certificate number IND17.0322/U. We have implemented the ISO/IEC 27001: 2013 standard for all processes supporting the development and delivery of services by Gruhfin.
If you have grievance or complaint, questions, comments, concerns or feedback in relation to the processing of information or regarding this Privacy and Security Policy or any other privacy or security concern, send an e-mail to [email protected].