Privacy Policy

1. DEFINITIONS

• 1.1. Borrower: A person registered as a Borrower on the Platform.
• 1.2. Credit Bureau Companies: Refers to CIBIL, Experian, Equifax, and CRIF Highmark.
• 1.3. Escrow Account: The account maintained for collecting and disbursing funds between lenders and borrowers.
• 1.4. Lender: A person registered as a lender on the Platform.
• 1.5. Platform: The peer-to-peer lending Website/App operated by 1FP2P.
• 1.6. RBI: Reserve Bank of India.
• 1.7. User / You: Means any person who registers on the Platform to act as a Lender or a Borrower.

2. INFORMATION WE COLLECT

We adhere to the principle of data minimization, collecting only the information necessary for operating the Platform, assessing creditworthiness, and complying with statutory obligations.

2.1. Information Provided by You

• Personal Information
• Contact Details
• Financial Information
• KYC Data

2.2. Information Collected Automatically

• a. Device and Technical Information: We may collect information such as device type, operating system, browser type, language preferences, and other technical identifiers to ensure platform compatibility and optimize user experience.
• b. IP Address: We collect your Internet Protocol (IP) address for security purposes, fraud detection, prevention of unauthorized access, and session management.
• c. Location Data: We may collect approximate or precise location data (subject to your device permissions) to enhance user experience, enable region-specific services, and comply with applicable legal or regulatory requirements.
• d. Usage and Activity Data: We collect information about your interactions with the Platform, including pages visited, features used, time spent, and navigation patterns, to improve functionality and service delivery.
• e. Cookies and Similar Technologies: We use cookies, web beacons, and similar tracking technologies to enhance user experience, remember preferences, analyze usage patterns, and improve platform performance.

3. BASIS FOR DATA COLLECTION AND CONSENT

We process your personal data lawfully, fairly, and for specified purposes in compliance with the Applicable RBI Directions and the Digital Personal Data Protection Act, 2023.

• 3.1. Consent: We obtain your consent for processing personal data where required under the DPDP Act. Certain data may also be processed without consent where permitted under applicable law, including for compliance with legal obligations, regulatory requirements, fraud prevention, and enforcement of legal rights.
• 3.2. Audit Trail: We maintain a complete audit trail of all consent obtained from you, including timestamps and records of changes or withdrawal of consent.
• 3.3. Right to Withdraw: You have the right to withdraw your consent at any time or request the deletion of your data, subject to our legal and regulatory obligations to retain certain information.
• 3.4. Grievance under DPDP Act: Users may exercise their statutory rights under the DPDP Act by contacting our Grievance Redressal Officer. We shall address such requests in accordance with timelines prescribed under applicable law.

4. USE OF INFORMATION

We use the information collected for the following purposes:

• 4.1. To Provide Services: Facilitating the matching of Lenders with Borrowers, processing transactions, and maintaining escrow accounts as mandated by RBI.
• 4.2. Credit Assessment: Evaluating the creditworthiness of Borrowers to assign a credit score and displaying relevant credit information to Lenders, as permitted.
• 4.3. KYC and Compliance: Verifying your identity to comply with RBI's KYC norms, Anti-Money Laundering (AML) standards, and for reporting to Credit Information Companies (CICs).
• 4.4. Communication: Sending you service-related communications, including Key Facts Statements (KFS), loan sanction letters, account statements, and recovery notices.
• 4.5. Improvement and Analytics: Analysing usage to improve the functionality and user experience of our Platform.
• 4.6. Legal Obligations: Responding to legal investigations, court orders, or governmental requests as required by Indian law.
• 4.7. Fraud Prevention and Risk Management: Detecting, preventing, and mitigating fraud, unauthorized transactions, and other risks to the Platform and its users.

We do not process personal data for any purpose other than those expressly stated herein, unless required under applicable law.

5. STORAGE OF INFORMATION AND DATA SECURITY

• 5.1. Location of Servers: In compliance with the RBI Digital Lending Directions, all personal data collected by us is stored on servers located within India in compliance with applicable RBI Directions.
• 5.2. Security Measures: We implement industry-standard security practices, including Secure Socket Layer (SSL) encryption and other technical safeguards, to protect data (including personal data, IP addresses, cookies, and location data) during transmission and storage. Access to your information is restricted to authorized personnel only.

6. COOKIES AND TRACKING TECHNOLOGIES

6.1. We use cookies and similar technologies to:

• Enable essential platform functionality;
• Remember user preferences and settings;
• Analyze platform usage and performance; and
• Enhance security and prevent fraud.

6.2. You may control or disable cookies through your browser settings. However, disabling certain cookies may affect the functionality of the Platform.

6.3. Where required under applicable law, we shall obtain your consent for the use of non-essential cookies through appropriate consent mechanisms (such as cookie banners). By continuing to use the Platform after providing such consent, you agree to our use of cookies in accordance with this Privacy Policy.

7. DISCLOSURE AND SHARING OF INFORMATION

We do not sell, trade, or rent your personal information to third parties. We share information only in the following circumstances:

• 7.1. With Lenders and Borrowers: To facilitate the loan transaction, we share necessary information between counterparties (e.g., a Lender will see details of the Borrower's loan request).
• 7.2. With Credit Information Companies (CICs): We share borrower credit information with Credit Information Companies in accordance with applicable RBI regulations and the Credit Information Companies (Regulation) Act, 2005, as required.
• 7.3. With Regulatory and Government Authorities: We may disclose information to the RBI, or other governmental bodies, as required by law or to comply with a legal obligation.
• 7.4. With Escrow Trustees and Banks: To facilitate fund transfers through the mandated escrow account system.
• 7.5. With Service Providers: We may share information with third-party service providers (including technology providers, KYC agencies, analytics providers, and payment processors) strictly on a need-to-know basis and subject to appropriate confidentiality and data protection obligations.

All third-party disclosures are limited to the minimum information necessary for the stated purpose.

8. DATA RETENTION AND DESTRUCTION

We retain personal data (including technical data such as IP addresses, cookies, and location data) for such period as required under applicable RBI regulations, the Prevention of Money Laundering Act, 2002, the DPDP Act, and other applicable laws.

Retention periods may extend beyond the duration of the user relationship where required for regulatory reporting, audit, fraud detection, dispute resolution, or legal enforcement purposes.

You may request deletion of your personal data, including withdrawal of consent for location tracking or cookies, subject to legal and regulatory retention obligations.

Upon expiry of the applicable retention period, data shall be securely deleted or anonymized.

9. YOUR RIGHTS

As a User of our Platform, you have the following rights regarding your personal data:

• 9.1. Right to Access: You may request a copy of the personal data we hold about you.
• 9.2. Right to Correction: You may request that we correct any inaccurate or incomplete data.
• 9.3. Right to Erasure/Deletion: You have the right to request the deletion of your data, subject to overriding legal or regulatory retention requirements.
• 9.4. Right to Withdraw Consent: You may withdraw your consent for data processing at any time. However, this may impact your ability to use our services, as certain information is essential to facilitate lending and borrowing.
• 9.5. Control Over Tracking Technologies: You may manage cookie preferences through your browser settings and control location data collection through device permissions. You may also request restriction or deletion of such data, subject to applicable legal limitations.

The exercise of rights under this section is subject to restrictions and exemptions prescribed under applicable law, including situations where continued processing is required for regulatory compliance or legal obligations.

10. GRIEVANCE REDRESSAL MECHANISM

If you have any questions, concerns, or complaints regarding this Privacy Policy or your data, you may contact our Grievance Redressal Officer.

Grievance Redressal Officer

Email: grievance@1financep2p.com

Phone: 022 45913333

Address: 1 Finance P2P Private Limited, A-1501/1502, Lotus Corporate Park, Ram Mandir Road, Goregaon-East, Mumbai 400063.

The Grievance Redressal Officer shall also act as the contact point for matters relating to personal data protection under the DPDP Act.

11. FAIR PRACTICES AND DISCLAIMERS

• 11.1. No Guarantee: You explicitly acknowledge and agree that we, as an NBFC-P2P Platform, do not assure the return of principal or payment of interest. All credit risk is borne by the Lender.
• 11.2. No Cross-Selling: We do not provide any form of credit enhancement, principal protection, or guarantee of returns to Lenders, nor do we represent that any loan transaction is risk-free.
• 11.3. No Dark Patterns: Our Platform ensures that all content displayed is unbiased and objective. We do not use "dark patterns" or deceptive design techniques to mislead you into choosing specific loan offers or services.
• 11.4. Links to Third Parties: Our Platform may contain links to other websites. We are not responsible for the privacy practices or content of those third-party sites.