MMFSL Privacy Policy
This Privacy Policy (“Policy”) applies to persons who access and/ or use our products and/ or services (“Services”), and/ or who access, browse and/ or use this mobile application/ software program, including any associated websites, domains, sub-domains, platforms, links, etc. as may be owned and/ or operated by MMFSL and as may be updated/ modified from time to time (“MMFSL-APP”).
Thank You for using our MMFSL-APP. Mahindra And Mahindra Financial Services Limited (“we”, “us”, “our”, “MMFSL”, “Mahindra Finance”) is committed to protecting Your privacy. This privacy policy (“Policy”, “Privacy Policy”) applies to persons who access, browse and/ or use the MMFSL-APP and are referred to as “You”, “Your” or “User”. This Privacy Policy shall be referred and read as an integral part of the Terms of Use (“Terms of Use”) of the MMFSL-APP.
This Policy will explain how Mahindra Finance will collect, store, disclose, transfer, and/ or use data that personally identifies You (“Personal Data”, “Personal Information”) when You visit our MMFSL-APP, use our Services and/ or view our online advertisements (including affiliate links). The information which Mahindra Finance collects and stores during normal use of the MMFSL-APP is used to monitor use of the MMFSL-APP and to help in the further development of our Services. We use this information to improve our MMFSL-APP-based offerings.
1. SCOPE:
This policy applies to information collected by Mahindra Finance
2. GRANT OF CONSENT:
By using, browsing and/ or otherwise accessing the MMFSL-APP, You hereby give Your consent to MMFSL to make phone calls, send SMSs, message through WhatsApp and similar messaging and other services, emails, USSD, voice services, push notifications, cell broadcast, MMSs, location-based services and to enable mobile solutions to inform and/ or share with You such information which MMFSL may think benefits You or otherwise in general with respect to other products and services offered by MMFSL, MMFSL’s affiliates, MMFSL’s marketing partners, etc. You also give Your consent and authorize MMFSL to allow MMFSL to offer You targeted/ personalized offers for products and Services. You further grant Your unequivocal and unconditional consent to MMFSL to enable, authorize and permit MMFSL to collect, process and use your Personal Information for the purposes as specified in this Privacy Policy.
With respect to any Services availed and/ or to be availed by You from MMFSL (whether through the MMFSL-APP or otherwise), You consent and authorize MMFSL (whether acting by itself or through any of MMFSL’s service providers and whether in automated manner or otherwise) to do and undertake any of the following, in relation to Your Personal Information about You, information, papers and data relating to know your customer (KYC), credit information, and any other information whether about You or not as may be deemed relevant by MMFSL for its purposes (hereinafter collectively referred to as “Information”):
a) to collect the Information from You and other physical or online sources including accessing the same from credit information companies, information utilities, websites, databases and online platforms (whether public or not); to get the authenticity, correctness, adequacy, etc. of the Information verified from any sources and persons (including Aadhaar authentication) including from online databases; and to act for and on my/ our behalf for such accessing, collecting or verifying of the Information. Such collection, access and verification may be done without any notice to You;
b) process Information including by way of storing, structuring, organising, reproducing, copying, using, profiling, etc. as may be deemed fit by MMFSL;
c) to store the Information for such period as may be required by contract, by law and/ or for MMFSL’s legal, compliance, evidential and similar purposes, whichever is longer;
d) to share and disclose the Information to service providers, consultants, credit information companies, information utilities, banks and financial institutions, affiliates, subsidiaries, regulators, investigating agencies, judicial, quasi-judicial and statutory authorities, or to other persons as may be necessary in connection with the contractual and/ or legal requirements and/ or in the legitimate interests of MMFSL and/ or as per the consent;
e) to subject You to automated processing, automated profiling and to the automated decision making by or on behalf of MMFSL;
f) to disclose any information relating to You (including Your account status and default committed by You) to any person or entity for any reasons or purpose whatever (including for the purpose of credit approval and/ or sharing).
g) any of the aforesaid may be exercised by MMFSL for the purposes mentioned above, for the purposes of credit appraisal, fraud detection, anti-money laundering obligations, for entering into contract, for direct marketing, cross-selling, for developing credit scoring models and business strategies, for monitoring, for evaluating and improving the quality of services and products, and/ or for other legitimate purposes and/ or for any purposes with consent.
In case You are using, browsing and/ or otherwise accessing the MMFSL-APP on behalf of your firm, partnership firm, company, trust, association, society, etc., You hereby represent, warrant, agree and confirm that You have and possess the required authorizations, approvals, permissions, etc. to grant the consent as required and specified in this Privacy Policy and the respective Terms of Use of the MMFSL-APP. MMFSL will be fully and absolutely entitled to assume that any person using the MMFSL-APP on behalf of their respective firm, partnership firm, company, trust, association, society, etc. shall be fully authorized in this behalf and any such use by You will fully bind the respective entity You represent (whether the same is a firm, partnership firm, company, trust, association, society, etc. or any other entity whatsoever) under this Privacy Policy and the respective Terms of Use of the MMFSL-APP. MMFSL shall not be responsible and liable for any consequences whatsoever which may arise owing to change in name/s or authorised signatory/ies or partners or directors or trustees or members of the firm/ company/ trust/ association/ society, etc. which You may represent.
3. COLLECTION AND USE OF PERSONAL DATA:
“Personal Data”/ “Personal Information” is defined as about or relating to a natural person who is directly or indirectly identifiable, having regard to any characteristic, trait, attribute or any other feature of the identity of such natural person, whether online or offline, or any combination of such features with any other information, and shall include any inference drawn from such data for the purpose of profiling, such as, including but not limited to, the individual’s name, home address, guardian’s name (if minor), email address, domain address, telephone number, date of birth, job position, occupation, etc. indicating to and/ or identifiable with a particular person.
Any content posted/ uploaded/ conveyed/ communicated by Users on the public sections of the MMFSL-APP, if any, become published content and will not be considered Personal Data subject to this Privacy Policy.
INFORMATION WE COLLECT FROM USERS
Mahindra Finance may collect Personal Data that You submit to us through the use of the MMFSL-APP, which may include:
- Name;
- Residential and/ or office address;
- Guardian’s name (if minor);
- Email address;
- Domain address;
- Telephone number;
- Date of birth;
- Job position;
- Occupation;
- Company (i.e., employer information);
- PAN, Aadhaar number and other such information;
- Data pertaining to nominees of the User;
- User credential, or any information that You submit to us.
Other Personal Data we collect may include:
- Financial information such as bank account details, salary statements, credit score and/ or Your financial investment strategy and investment background;
- Documents that You provide to us to verify Your identity, such as copies of Your passport, PAN card, Aadhar details, driving license, utility bills, voter ID and/ or bank statement(s).
- Photograph of You and/or Your residence, vehicle, etc. as may be required for any particular Service availed by You through the use of the MMFSL-APP;
- We may collect some information automatically when You visit our MMFSL-APP, which include:
- IP address;
- Information about Your web browser software and version;
- General geographic location indicated by Your IP address;
- Website(s)/ link(s) that referred You to us, and similar information;
- Mobile/ tab device details;
- Anonymous site statistical data.
- We also may collect information about Your activity on our MMFSL-APPs, which may include:
- Frequency of visits to our MMFSL-APP;
- Average length of visits;
- Pages/ sections viewed during a visit.
- We may use various technologies to collect information about Your activities on our MMFSL-APP, including any cookies, web beacons, web bugs, etc.
- We may also collect information about You that we may need from You at the time of offering customer support for any Service(s) as may be availed by You.
- When You wish to share Your story as a part of “Customer Speak”, we may collect and store Your information like name, location, occupation, etc.
- If You seek any help via the MMFSL-APP, we may collect and store such information, including but not limited to, name, email address, phone number (if mentioned by You).
- Further, MMFSL reserves the right, from time to time, to collect Personal Data by way of one-time access for camera, contacts, photos, microphone, location, notifications, files, media and storage, phone, SMS, etc. of your mobile phone/ tab device for the purpose of on-boarding, servicing, and KYC (“know your customer” under respective KYC guidelines) for any Services as may be availed by You. You are requested to provide your consent to MMFSL, when requested, to enable MMFSL to carry out such activities.
Information From Other Sources
We may obtain information about You from other sources, including customer reporting agencies such as credit bureaus, Your employer and/ or third parties, data aggregators and/ or public databases. We may also collect information about You from our affiliates and/ or non-affiliated third parties. This may include Personal Data, such as credit scores, etc.
Other Platforms, Websites, etc.
MMFSL may invite Your participation in various promotional initiatives through its presence on social networking websites and blogs operated by third parties, such as LinkedIn, Facebook, Twitter, etc. based on Your consent.
In addition, MMFSL may provide You with links to “share” any MMFSL content with other third parties via email and/ or certain social networking websites for Your convenience. Data transmitted during such linking, including but not limited to Your email address or the email address of the party receiving such data, shall not be tracked by MMFSL.
The text and graphic links as may be included in the MMFSL-APP may link to third party social media sites and information and/ or service providers that may also collect information from You, over which MMFSL has no control. In addition, some of the pages on the MMFSL-APP may lead to co-branded web pages that are hosted and served by third parties. In each of the aforesaid circumstances, MMFSL has no control over the privacy policy of any third-party entity, and MMFSL is not responsible in this regard. Use of MMFSL data by any third party shall be at their discretion and risk. Personal Data collected by these third parties is not covered by this policy, and MMFSL shall not be bound in any manner by any claims and/ or liabilities arising therefrom. If we share information with third parties (other than our service providers) as described above, we cannot control the privacy practices of those third parties, and they may not comply with the restrictions that we describe here. We encourage You to be aware when You leave our MMFSL-APP and to read the privacy policies of other websites that may collect Your Personal Data.
4. USE OF COLLECTED PERSONAL DATA:
MMFSL may use the Personal Data that is collected from You with Your consent to provide requested Services and for our internal business purposes, including, but not limited to:
- Responding to Your requests for our Services;
- To process Your transactions and to provide You with transaction and post transaction-related services, providing, improving, and marketing our Services, including site content and performance;
- Evaluating Your use of the Services;
- Providing advertising for products and services that might interest You;
- Responding to Your requests for information;
- Communicating with You by email, postal mail or courier, and/or telephone about products or services that may be of interest to You;
- Maintaining and managing Your account with us;
- Keeping You updated on the issues that are relevant to Your business relationship with us;
- Monitoring Your compliance with any terms and conditions associated with our Services, including to confirm Your identity;
- Performing other functions as described to You at the time of collection or pursuant to Your consent;
- Delivering marketing and event communications to You across various platforms, such as email, telephone, text messaging, WhatsApp (and/ or similar messaging services) and/ or direct mail. Based on Your consent, we may send You marketing emails, which include instructions on how to opt out of receiving these emails in the future. Please remember that even if You opt out of receiving marketing emails, we may still send You important service information related to any Services availed by You, Your accounts and subscriptions, etc.;
- Using Your data for regulatory/ statutory reporting activities, anti-money laundering (AML) and fraud investigation purpose;
- Using Your Personal Data to meet our internal and external audit requirements and for information security purposes.
- For legal and compliance reasons, such as the prevention, detection and/ or investigation of a crime, loss prevention or prevention of fraud.
If MMFSL wishes to collect and process Your Personal Data for purposes other than those mentioned above, we shall seek a specific consent from You prior to collecting and/ or processing Your Personal Data for such additional purposes unless such additional processing requirements fall within legitimate business and/ or statutory requirements for processing as explained above.
Based on Your consent, we may combine Your information, automatically gathered information and the information we collect through cookies/ web beacons/ web bugs, etc. including information that we have collected or obtained about You from other sources. We may aggregate any statistics or data that are collected.
5. PROCESSING OF YOUR PERSONAL DATA IN CERTAIN CIRCUMSTANCES:
We may process Your Personal Data in any of the following uses:
- To comply with a legal obligation to which we are subject, or
- To comply with any law for the time being in force made by the parliament or any state legislature, or
- To process Your information based on your consent, or
- To respond to any medical emergency involving a threat to Your life, or
- To undertake any measure to provide medical treatment or health services to any individual during an epidemic, outbreak of disease or any other threat to public health; or
- To undertake any measure to ensure safety, or provide assistance or services to, any individual during any disaster or any breakdown of public order, or
- To process Your Personal Data for reasonable purpose such as:
- prevention and detection of any unlawful activity including fraud;
- whistle blowing;
- mergers, acquisitions, any other similar combinations or corporate restructuring transactions in accordance with the provisions of applicable laws;
- network and information security;
- credit scoring;
- recovery of debt;
- processing of publicly available Personal Data.
6. SHARING/ DISCLOSURE OF YOUR PERSONAL DATA:
We will transfer Your Personal Data to the following recipients:
- MMFSL group companies and potential acquirers: Our businesses are supported by a variety of MMFSL sub teams, functions, MMSFL’s subsidiaries and group companies. Personal Data will be made available to them basis Your consent or, if necessary, for the provision of Services, account administration, sales and marketing, customer and technical support, and business and product development.
- Service providers: We may share Your Personal Data with organizations, entities or individuals that perform functions and/ or certain services on our behalf. For example, service providers may conduct verification and/ or evaluation of information You share with us, verification of Your property details, processing of Your payments for our Services, etc. These service providers are granted access to Personal Data for the purpose of performing their services and/ or functions for MMFSL.
- External providers of IT software, hardware, infrastructure, etc.: We collaborate with external providers of IT software, hardware, infrastructure, etc. around the world for any support needed and/ or as part of our internal operations that are part of our Service offerings to You. Your Personal Data will be processed by these parties only insofar as it is necessary for them to provide their services to us, such as support for software, systems, and platforms; delivery of marketing messages; cloud hosting services; and order fulfilment and delivery, etc.
- Legal Matters: MMFSL may share Personal Data (a) in response to a court order and/ or in respect of a request for cooperation from a law enforcement or other government agency, or (b) as otherwise required by law; (c) to persons acting as representative capacity on Your behalf; (d) to defend against legal claims; (e) to investigate, prevent, or take other action regarding illegal activity, suspected fraud, suspected violations of terms and conditions associated with any of our Services, or other wrongdoing; or (f) to protect and defend the rights, property or safety of our company, our users, our employees, or others.
- Transactions: MMFSL may share Personal Data in connection with a substantial corporate transaction, such as mergers, acquisition, the sale of our business, a divestiture, consolidation, or asset sale, or in the unlikely event of bankruptcy.
- Marketing: MMFSL may share collected Personal Data with group companies whose products and services we believe you may find of interest. If you would prefer that we not share your Personal Data with any third parties for the third parties’ marketing purposes, you can notify us of your preference by contacting us as per details mentioned below.
- Other Purposes: MMFSL may share Personal Data as otherwise described to You at the point of collection (including at the time you avail of any of MMFSL’s Services) and/ or pursuant to Your consent.
7. PERSONAL DATA TRANSFER, STORAGE AND PROCESSING GLOBALLY:
We may transfer Your Personal Data to our holding company as well as other group companies and affiliates, and its/ their subsidiaries or third parties in locations around the world for processing the Personal Data as per the purposes described in this Privacy Policy. Wherever Your Personal Data is transferred, stored or processed outside Your jurisdiction, we will take reasonable steps to safeguard the privacy of Your Personal Data.
8. SECURITY MEASURES:
MMFSL uses commercially reasonable security measures (including physical, electronic and procedural measures) to help safeguard Personal Data against loss, misuse, damage or modification and unauthorized access or disclosure. However, no system for transmitting or storing information electronically can be completely secure. Therefore, we cannot guarantee that personal information or other communications will always remain secure.
9. RETENTION OF PERSONAL DATA:
MMFSL generally may not retain any Personal Data beyond the period necessary to satisfy the purpose for which it is processed and may delete the Personal Data at the end of the processing. However, MMFSL will keep Your Personal Data for as long as required for the purposes set out above and/ or even beyond the expiry of any transactional and/ or account based relationship with you: (a) as required to comply with applicable laws and/ or any legal and regulatory obligations to which MMFSL is subject, or (b) for establishment, exercise or defence of legal claims, or (c) as specified in this Privacy Policy, or (d) in accordance with specific consents.
It is however specified that unless required by applicable laws and/ or legal and statutory obligations, MMFSL is not obliged to maintain any Personal Data as a result of Your access and usage of the MMFSL-APP.
10. SERVICES OF MMFSL:
When You avail any Services of MMFSL through the use of the MMFSL-APP, some or all of such Services may carry their own additional and/ or specific terms and conditions, privacy policies, etc., including any offline documentation process and other related requirements. These will be applicable to You and will apply in addition to the terms and conditions of this Privacy Policy. In the event of any inconsistency between these different terms and conditions, privacy policies, etc. those that are distinct and specific to the particular Service availed by You shall prevail and apply respectively to such Service.
11. CHANGES TO THIS PRIVACY POLICY:
MMFSL reserves the right to change or update this Privacy Policy from time to time at any time, without prior notice. Such changes to the Privacy Policy may be in furtherance of changes in our practices concerning the collection and use of Your Personal Data and/ or under the requirements of applicable laws. Users are requested to periodically check the terms and conditions under this Privacy Policy from time to time. Such changes shall be effective immediately as and when such changes/ updates are published/ posted/ hosted on our MMFSL-APP/ respective platforms. If You use the MMFSL-APP and/ or other connected platforms or make any application/ request for any Service or use any Service or make any service requests (support, etc.) by or through the MMFSL-APP (including any connected platforms) for or during usage of any Service or if You use any functionality of the MMFSL-APP (including any connected platforms) provided by or for us, such act of any of aforesaid uses shall by itself amount to Your acceptance of the Privacy Policy with changes, if any. The headings in the Policy are only for convenience and shall not be used to construe the meaning or intent of terms and conditions hereof.
12. RIGHTS UNDER APPLICABLE LAWS:
If you are concerned about our use of your personal information, please contact us at [email protected], with the subject line, “privacy”.
Please note that applicable law might require that we cannot comply with every request. For example, we will be required to keep Your Personal Data due to statutory, legal and/ or regulatory retention requirements despite Your request for erasure.
To exercise your rights under this Privacy Policy, including the rights as available to you under applicable laws, we will need You to respond with proof of Your identity before You can exercise these rights. MMFSL may not be able to process any requests made in the event the User fails to identify themselves or if MMFSL is unable to authenticate such a User. MMFSL may also decline to process requests that are unreasonably repetitive or systematic, requiring disproportionate effort, jeopardizing the privacy of others, or would be extremely impractical or for which access is not otherwise required. MMFSL shall not charge You for fulfilling any of the above requests. However, if the fulfilment of any such request leads to certain costs being incurred by MMFSL, then MMFSL will notify You prior to processing such request.
MMFSL reserves all its rights as available to MMFSL under law and in equity.