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Fair Practice Code (FPC)

1. Introduction and Philosophy

Clickra Solutions Private Limited ("the Company") acts as a Lending Service Provider (LSP) and is committed to the highest standards of integrity and transparency in its operations. We facilitate digital lending services in partnership with SONU MARKETING PVT LTD, a Non-Banking Financial Company (NBFC) registered with the Reserve Bank of India (RBI), which acts as the actual lender.
While financial contracts can be complex, we are committed to ensuring that customers interacting through our digital platform are treated fairly, provided with clear and transparent information, and supported by robust grievance redressal mechanisms.
This Fair Practices framework aligns with the Reserve Bank of India (Non-Banking Financial Companies – Responsible Business Conduct) Directions, 2025, and the RBI Digital Lending Guidelines. The applicable Fair Practices Code is issued by SONU MARKETING PVT LTD (NBFC), and we operate strictly in compliance with such Code in our capacity as a Lending Service Provider.

2. Applicability

This Code applies to all products and services offered by the Company, specifically including those offered through Digital Lending Applications (DLAs) owned by the Company or its Lending Service Providers (LSPs). It applies to all employees, directors, agents, and third-party vendors authorized to represent the Company.

3. Customer Empowerment: Applications and Processing

3.1 Transparency in Product Offerings

The Company ensures that all loan products, interest rates, and fees are clearly listed on our website and Digital Lending Applications (DLAs). We use plain and simple language (vernacular/regional language where applicable) to explain our products. Our goal is to empower you to compare our offerings with other market participants before making a commitment. We will provide a comprehensive checklist of required documents upfront to ensure a seamless and predictable application process.

3.2 Formal Acknowledgement and Timeline

Upon submission of a digital loan application, the Company will issue an immediate electronic acknowledgement by notification in the Customer's Personal Cabinet, or through other communication channels, where such channels are used. This receipt serves as a formal record of your application and includes a unique tracking ID. We are committed to a time-bound processing system; the acknowledgement will clearly state the expected timeframe within which your application will be reviewed and a final decision (sanction or rejection) will be communicated.

3.3 Responsible Credit Assessment

As a responsible lender, we perform a diligent credit appraisal to ensure that the loan amount is within your repayment capacity, thereby preventing over-indebtedness. This assessment is based on the data you provide and information from Credit Information Companies (CICs). Any enhancement in your credit limit will only occur following a fresh credit assessment and your explicit, recorded consent.

4. The Sanction Process and "No Hidden Costs"

4.1 The Key Fact Statement (KFS) - Your Absolute Reference

Before you execute any loan agreement, we will provide you with a Key Fact Statement (KFS). This is a standardized, easy-to-read document that acts as the single source of truth for your loan.
  • Annual Percentage Rate (APR): The KFS will prominently display the APR, which represents the total cost of the loan (interest + processing fees + any other charges) expressed as an annual percentage.
  • Binding Nature: The Company is legally bound by the KFS. We will not charge any fee, cost, or interest that is not explicitly mentioned in this document.
  • Validity Period: You will have a "Validity Period" at least 15 days to review the KFS and decide whether to proceed.

4.2 Clear Documentation

Upon approval of the loan, the Company shall provide the borrower with a copy of the Sanction Letter and the Loan Agreement, along with copies of all relevant enclosures referred to therein. The loan documentation shall clearly set out the terms and conditions of the loan, including the repayment schedule and the method of interest calculation. Copies of the executed loan documents shall be furnished to the borrower at the time of sanction and/or disbursement of the loan.

5. Disbursement and Changes in Terms

5.1 Disbursement

  • Any and/or all disbursement of loans shall always be made directly into the bank account of the borrower.
  • There shall be no disbursal to a third-party account, including accounts of LSPs, except as provided under statutory mandates or co-lending guidelines.

5.2 Changes in Terms

  • The Company provides notice to the borrower in the vernacular language or a language understood by the borrower of any change in terms and conditions, including disbursement schedule, interest rates, service charges, prepayment charges, etc.
  • We ensure that any change in interest rates and charges takes effect only prospectively.

6. Specific Provisions for Digital Lending

6.1 The Cooling-Off / Look-up Period

We recognize that sometimes a borrower may have second thoughts after a loan is disbursed. The Company provides a mandatory Cooling-Off Period. During this window, you may exit the loan by repaying the principal amount and the proportionate Annual Percentage Rate without paying any foreclosure or pre-payment penalty. This ensures you are never "trapped" in a financial commitment you regret.

6.2 Ethical Data Practices and Privacy

In the digital lending ecosystem, your data privacy is paramount.
  • Explicit Consent: We only collect data that is absolutely necessary for loan processing, and only after obtaining your "Opt-in" consent at each stage.
  • Restricted Access: Our mobile applications are prohibited from accessing your private mobile resources such as contacts, media files, call logs, or telephony functions.
  • Data Locality: All customer data is stored on secure servers located within India. You also have the "Right to be Forgotten," allowing you to request the deletion of your data once the loan is fully repaid, subject to statutory record-keeping requirements.

7. Interest Rates, Penal Charges, and Repayment

7.1 Fair Interest Pricing

The Company's Board has approved an Interest Rate Model that considers the cost of funds, operational expenses, and the risk profile of the borrower. All interest is calculated on a daily/monthly reducing balance basis, ensuring you only pay interest on the outstanding principal.

7.2 Penal Charges (Not Penal Interest)

In the event of a payment delay, the Company may levy Penal Charges. Following the 2025 RBI Directions, these are "charges" and not "interest".
  • No Compounding: We do not add these charges to the principal balance to calculate further interest. This prevents the "debt spiral" where interest is charged on top of penalties.
  • Transparency: The exact amount and reason for any penal charge will be clearly highlighted in bold in your KFS and Loan Agreement.

8. Responsible Collections and Recovery

8.1 Conduct of Recovery Agents

If you face difficulties in repayment, our first approach is always dialogue and persuasion. If we engage a recovery agent, we ensure they are professionally trained to deal with the customers in an appropriate manner.
  • No Harassment: Agents do not resort to intimidation or harassment of any kind, either verbal or physical, against any person in their debt collection efforts, including acts intended to humiliate publicly or intrude upon the privacy of the debtors' family members, referees and friends, sending inappropriate messages either on mobile or through social media, making threatening and/or anonymous calls.
  • Restricted Timing: Calls or visits for recovery will only happen between 08:00 AM and 07:00 PM.

9. Grievance Redressal and the Internal Ombudsman

9.1 Tiered Redressal Mechanism

We value your feedback and take complaints seriously.
  • Level 1 (Grievance Redressal Officer): You may contact our GRO via the email provided on our website. We commit to resolving all issues within 30 days.
  • Level 2 (Internal Ombudsman): In compliance with the RBI (Internal Ombudsman) Directions, 2026, any complaint that is rejected or only partially resolved by the Company will be automatically reviewed by our Internal Ombudsman (IO). The IO is an independent, high-level authority who ensures that the Company's decision was fair and compliant with the FPC.
  • Level 3 (RBI Ombudsman): If you remain unsatisfied after 30 days, you have the right to approach the Reserve Bank - Integrated Ombudsman Scheme via the CMS portal at https://cms.rbi.org.in.

10. Outsourcing

  • The Company ensures that outsourcing arrangements do not diminish its obligations to customers or the RBI.
  • The Company is responsible for the actions of its service providers, including LSPs and recovery agents.
  • The Company ensures confidentiality and security of customer information possessed by service providers.
  • The Company does not outsource core management functions like internal audit, strategic and compliance functions, or decision-making functions like loan sanctioning.

11. Policy Review

This Code is reviewed annually by our Board of Directors to incorporate any new regulatory changes or technological advancements. We are committed to not just following the letter of the law, but the spirit of fairness it represents.