Privacy Policy

We are pleased to welcome you to our website and would like to provide you with essential information regarding our commitment to the security and privacy of personal data.

Please review this section regularly, as this policy may be subject to changes or updates. Any significant changes to this policy will be duly notified through prominent display on our website or through direct communication. In addition to this policy, please consult our Cookie Policy and Grievance Redressal Policy.

1. Who we are (Information on the data fiduciary)

CLICKRA SOLUTIONS PRIVATE LIMITED, a company incorporated under the laws of India, having its registered office at 91Springboard, Trifecta, 21, ITPL Main Rd Garudach, Mahadevapura, Bangalore North, Bangalore- 560048, Karnataka (hereinafter, the "LSP"), acts as a Loan Service Provider to the SONU MARKETING PVT LTD, a company incorporated under the Companies Act, 2013, (CIN) U51909WB1995PTC068572, RBI registration number B.05.04069, Date of Issue: 01.03.2001, which is registered with the Reserve Bank of India (hereinafter, the Non-Banking Financial Company or NBFC).

The LSP provides technological, IT and platform-related services, including the operation of the website and supporting infrastructure, customer onboarding interfaces, data collection tools and loan processing functionalities, on behalf of the NBFC (hereinafter the "Platform").

This Privacy Policy applies to:

The NBFC as the lender and Data Fiduciary under the Digital Personal Data Protection Act, 2023 (DPDPA)
The LSP as the Data Processor providing technological and operational services related to the Website and loan processing on behalf of the NBFC.

Contact Details:

Website: https://clickra.in
Email: info@clickra.in

Grievance Officer:

Email: grievance@clickra.in
Contact Number: 91872 39286
Address: at 91Springboard, Trifecta, 21, ITPL Main Rd Garudach, Mahadevapura, Bangalore North, Bangalore- 560048, Karnataka.

2. Scope of use

This Policy informs you of our policies on your privacy rights regarding our collection, use, storage, processing, disclosure and security of your personal information when you use the Platform on any device (including mobile devices). This Policy applies to all Personal Information we process in connection with your relationship with us as a customer or potential customer.

This Policy constitutes a legal agreement between you, as the user of the Platform and the Company, as the owner of the Platform. You must be a natural person, citizen of India, who is at least 21 years of age.

3. Personal data we may collect

We may collect personal data that you provide directly, that is generated through your use of our services, or that is obtained lawfully from third-party sources connected with the services.

Such data may include, as applicable:

3.1 Identity and contact data

(a)full name;

(b)mobile number;

(c)email address;

(d)residential address;

(e)date of birth;

(f)PAN, Aadhaar or other government-issued identification details, where lawfully collected;

(g)photograph, selfie, video or liveness check outputs used for KYC or fraud prevention; and

(h)other contact or identity details provided during onboarding or servicing.

3.2 Financial and transaction data

(a)bank account details;

(b)repayment and transaction history;

(c)loan account details;

(d)disbursement and repayment records;

(e)payment instrument details, where relevant and lawfully processed; and

(f)other financial information required for underwriting, servicing or reconciliation.

3.3 Employment and profile data

(a)occupation, employer details and income-related information;

(b)business or work-related contact details, where applicable; and

(c)other profile information submitted as part of the application or servicing process.

3.4 Device, technical and usage data

(a)IP address;

(b)browser type;

(c)device identifiers;

(d)operating system;

(e)app or website usage logs;

(f)pages / screens visited;

(g)timestamps and session information; and

(h)other technical information reasonably necessary for security, analytics, fraud prevention or service functionality.

3.5 KYC, verification and credit-related data

(a)KYC verification outputs;

(b)fraud and risk assessment data;

(c)credit bureau or creditworthiness-related information, where lawfully obtained; and

(d)verification data received from authorised third-party verification partners.

3.6 Communications and support data

(a)customer-support communications;

(b)complaint / grievance details;

(c)call recordings, where notified and permitted;

(d)chat logs;

(e)email correspondence; and

(f)documents or information submitted in relation to requests, complaints or disputes.

3.7 Limited device permissions and access

Where necessary for specific functions and subject to applicable law and user permissions, we may request limited access to certain device capabilities such as:

(a)Camera access - to capture documents, perform selfie verification and complete KYC or fraud-prevention checks;

(b)Location data - to verify user location for fraud prevention, risk assessment and compliance requirements;

(c)IP address - to support security, fraud detection and service functionality;

(d)Device and browser details - to enable secure access, detect suspicious activity and improve platform performance;

(e)Uploaded files - where you choose to upload documents required for onboarding, verification or servicing;

(f)Real-time photo capture (not from gallery) - to ensure authenticity of user identity and prevent misuse or impersonation.

We request only those permissions that are necessary for providing our services and in compliance with applicable regulatory requirements.
We do not seek access to device features or data that are not reasonably necessary for the stated purpose or that are prohibited under applicable law or regulatory requirements.

4. How we collect personal data

We may collect personal data:

(a)directly from you when you fill forms, upload documents, register, apply for a loan, interact with support channels or otherwise communicate with us;

(b)through your use of our website, app or digital platform;

(c)from partner NBFCs, service providers, payment partners, KYC / verification partners, credit bureaus or fraud-prevention providers, where lawfully permitted;

(d)from public or regulatory sources, where relevant and lawful; and

(e)from cookies and similar technologies, as described in our Cookie Policy.

Where you provide details of references or other third parties, you should ensure that you are authorised to provide such information and that doing so is lawful and appropriate for the specific purpose.

5. Purposes of processing

We may process personal data for purposes including:

(a)onboarding users and processing loan applications;

(b)identity verification, KYC, fraud prevention and compliance checks;

(c)enabling platform access and account administration;

(d)facilitating communication between the user, Clickra and the partner NBFC;

(e)supporting loan servicing, repayment journeys, settlement, closure and account management;

(f)providing customer support and grievance handling;

(g)processing transactions and payment-related communications;

(h)conducting analytics, monitoring, troubleshooting and service improvement;

(i)complying with legal, regulatory, audit, reporting and enforcement requirements;

(j)exercising or defending legal rights and claims;

(k)preventing abuse, misuse, unauthorised activity or security incidents; and

(l)sending service-related communications and, where permitted, promotional communications.

We do not share personal data with third parties for their independent marketing purposes without an appropriate legal basis, including consent where required.

6. Grounds for processing and consent

Personal data may be processed on the basis of consent, where consent is required, and/or on other lawful grounds recognised under applicable law.

Where consent is required, we will seek consent through an appropriate notice, consent flow, checkbox, click-through mechanism or other valid digital means.

You may withdraw consent where processing is based on consent, subject to legal or operational consequences such as inability to continue providing certain services.

Withdrawal of consent will not affect processing already undertaken lawfully before such withdrawal.

7. Sharing of personal information

We may share your Personal Information with third parties, which includes, but is not limited to the following entities:

Affiliates and/or Members of our corporate family direct and indirect subsidiaries, to assist in providing the Services listed in the Platform, to help detect and prevent potentially illegal acts and violations of our policies, and to provide proper data analytics on the use of the Platform, including marketing communications.

Courts of Law, government officials, law enforcement, or other regulators in relation to a subpoena, court order, or other legal process or requirement under applicable laws or regulations, when we need to do so to comply with such law or regulation, or when we believe, in our sole discretion, that the disclosure of Personal Information is necessary to prevent physical harm or financial loss, or to report suspected illegal activity or investigate violations of our Terms and Conditions;

Credit bureaus and collection agencies to report account information, as permitted by law.

Customer support for customer service purposes;

Banking or financial partners, as permitted by law or as required by the contractual business relationship;

Legal department, to ensure compliance with government rules and regulations and to protect us against harm to the rights, property, or safety, the other users of the Platform or the public, as required or permitted by law;

Service Providers, to enable service providers under contract with us to support our business operations, such as fraud prevention, bill collection, marketing, customer service and technology services.

8. Service providers

We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform services-related actions, to assist us in analyzing how our Service is used, or to assist us in the collection of delinquent accounts.

These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose, use, or store your Personal Information for any other purpose.

9. Special notice – minors

Use of the Platform is not aimed at persons under 21 years old and we will not collect, use, provide or process in any other form any Personal Information of persons under the age of 21 deliberately.

We therefore also ask you, if you are under 21 years old, please do not send us your Personal Information (for example, your name, address and email address). If you are under 21 years old and you nevertheless wish to ask a question or use this Platform in anyway which requires you to submit your Personal Information, please get your parent or guardian to do so on your behalf.

10. Accuracy of personal information

You are responsible for ensuring that the information provided by you is accurate, complete and kept reasonably up to date. If you wish to update or correct any Personal Information you have supplied us with, please contact us immediately using our contact information:

Website: https://clickra.in
Email: info@clickra.in

11. Personal information storage

We retain personal data only for as long as necessary for the relevant purpose(s), or for such longer period as may be required under applicable law, regulatory requirements, audit obligations, dispute-resolution needs, fraud-prevention needs or lawful business record-retention requirements.

We may also retain Personal Information to comply with the requirements of any laws and regulations, to prevent fraud, to resolve disputes and various troubleshoot problems, and to take other actions permitted or required by applicable laws and regulations. Under our data protection policies, we will dispose Personal Information in a secured manner and in accordance with applicable laws and regulations, after such Personal Information is no longer necessary and ceases to be relevant for our Services, unless applicable laws and regulations require otherwise.

Where consent is withdrawn, or the specified purpose is no longer being served, deletion / erasure may be subject to any retention required by law or reasonably necessary for compliance, claims or dispute resolution.

12. Security and user confidentiality

Security of your Personal Information is our priority. Except as indicated in this Policy, we do not disclose your Personal Information to third parties without your express consent. Further, we take all reasonable procedures and exert our best efforts to ensure all Personal Information received shall be kept confidential and secure, whether online or offline.

We protect your Personal Information using a variety of technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. We may use and amend from time-to-time various security measures, as new technology becomes available, as appropriate, such as firewalls and data encryption, access controls to data centers.

To further secure the privacy of your Personal Information, we advise to always keep your account details confidential.

13. External links and policy updates

Our Platform may contain links to third-party websites or services that are not owned or controlled by us. We are not responsible for the content, privacy practices, or policies of such third parties. We recommend reviewing the privacy policies of any external websites you visit.

We may update this Privacy Policy from time to time by publishing the revised version on the Platform. The updated Policy becomes effective from the date of publication. Where material changes are made, we will take reasonable steps to inform users. Continued use of our Services after such updates constitutes acceptance of the revised Policy.

14. Your rights and choices

Subject to applicable law, you may have rights in relation to your personal data, including the right to:

(a)seek information regarding processing;

(b)request correction, updating or erasure, where applicable;

(c)withdraw consent, where processing is based on consent;

(d)seek grievance redressal; and

(e)nominate another person to exercise rights in the manner permitted under applicable law, where relevant.

Requests may be subject to verification, legal limitations and exceptions.

15. Grievance redressal and contact

If you have any questions, concerns or complaints regarding this Policy or the processing of your personal data, you may contact:

Privacy / Data Protection Contact:

Email: info@clickra.in

Grievance Officer:

Email: grievance@clickra.in
Phone: 91872 39286
Address: 91Springboard, Trifecta, 21, ITPL Main Road, Garudachar Palya, Mahadevapura, Bangalore North, Bangalore – 560048, Karnataka.

We will endeavour to review and address privacy-related grievances within a reasonable period and in accordance with applicable law and internal processes.

If you are not satisfied with the response, you may seek such remedies as may be available under applicable law.

16. Complaints, regulatory rights and governing law

If you believe that your Personal Information has been misused, compromised, or processed unlawfully, you may submit a complaint using the contact details provided in this Policy, including a brief description of the issue and your contact information.

If you are not satisfied with our response, you may lodge a complaint with the relevant regulatory authority in accordance with applicable Indian laws.

This Privacy Policy is governed by the laws of India. Any disputes arising in connection with this Policy shall be subject to the exclusive jurisdiction of the courts located in Bangalore, India.

We may update this Policy from time to time to reflect changes in law, regulation, technology, products, business operations or our data-processing practices.

The updated version will be made available on the relevant website or platform and shall be effective from the date stated therein. Where material changes are made, we may also take additional steps to notify users, where appropriate.

Office Hours: Monday to Friday, 10:00 AM to 6:00 PM IST (excluding public holidays).

17. Acknowledgment

By using our services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.