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Privacy Policy

1. OVERVIEW

  1. Great Meera Finlease Private Limited (Great Meera/Company) is engaged in providing unsecured credit facilities to MSMEs in B2B marketplaces, brands and mid-size corporates to meet their working capital requirements, including flexibility in repayment terms.     

  2. This Privacy Policy ("Policy”) is an integral part of the Great Meera terms of use (“Agreement”) and is incorporated therein by reference for access and use of this website. Capitalised terms not defined in this Privacy Policy shall have the meaning ascribed to them in the Agreement. This Privacy Policy shall be read in conjunction with the Agreement. 

  3. Great Meera Finlease Private Limited provides this privacy policy in connection with an individual’s use of any of GREAT MEERA’s products or services or its website. (“GREAT MEERA’s Privacy Policy”). 

  4. For the purposes of GREAT MEERA’s Privacy Policy, the term “you” or “your” relates to the individual (i)who applies for, or obtains, any of GREAT MEERA’s products or services (ii) who visits the website. The term “GREAT MEERA,” “we,” or “our” refers to Great Meera Finlease Private Limited, its affiliates and subsidiaries. 

  5. Under this Policy we inform you regarding the manner in which we collect, store, use, disclose, transfer and process your Personal Information when you use our website, or avail any products or services which we may operate or offer to you either directly through our Websites or Platforms or through a merchant or partner platform; including the steps we take to protect your Personal Information. 

  6. GREAT MEERA’s Privacy Policy applies to personally identifiable information about you, which we refer to as “your information”. In connection with GREAT MEERA’s treatment of your information, GREAT MEERA’s Privacy Policy describes the policies and procedures (including a summary of the relevant security controls) that GREAT MEERA’s uses when collecting, maintaining, using, or transmitting (or “disclosing”) to others any of your information. Please carefully read GREAT MEERA’s Privacy Policy before use of its services/ platform. 

2. INFORMATION WE COLLECT

  1. “Personal information” means any information that relates to an individual, which directly or indirectly, in combination with other information available or likely to be available with us, is capable of identifying such individual. Such information may include information such as your mobile telephone number, email address, residential address, nationality, photo, employee ID number, tax identification number, Aadhaar number, personal identification proof (Driving License and/or passport), PAN number etc.

  2. "LSP(s)” means an agent of the Company who carries out one or more of Company’s functions or part thereof in customer acquisition, underwriting support, pricing support, servicing, monitoring, recovery of specific loan or loan portfolio on behalf of the Company in conformity with extant outsourcing guidelines issued by the RBI

  3. “Sensitive Personal Information” means any Personal Information of an individual, which consists of information relating to financial information such as bank account, credit card, debit card or other payment instrument details; and subject to the nature of the transaction and where permitted for diversity and monitoring purposes, we may collect information concerning your gender, information about your employment or marital status or personal characteristics, such as whether you are employed, place of work, and the number of days you work in a month etc.; 

  4. However, information freely available or accessible in public domain is not treated as Sensitive Personal Information. As a matter of principle, we do not collect certain special categories of Personal Information about you (such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, information about your health or any genetic and biometric information).

  5. Depending on who you are (e.g., a merchant, customer, cardholder, consumer, supplier or business partner) and how you interact with us (e.g., through Website, Platform, telephone, IVR, online or offline), we may collect, use, receive, store, analyze, combine, transfer or otherwise process different categories of your Personal Information (including Sensitive Personal Information) whether directly:-
     

    1. provided by you on an application to us or from data we collect from transactions you conduct using our services; or

    2. from your devices when you use your device to connect to GREAT MEERA’s/ LSP’s Services, we receive information about that device, including IP address, hardware model, operating system, and other technical information about the device. We also use cookies or similar tracking technologies to collect usage statistics and to help us provide and improve our services. 

    3. We may collect several categories of your information, including Account information, including your financial institution’s name, the account type you use (such as a “checking account” or “savings account”), account number(s), and the institution’s routing number; Information about any balance or transactions in your account; and Information about the account owner(s), including name, email address, phone number, and mailing address information. 

    4. from other sources including LSP                            
       

  6. The Website or Platforms may include links to third-party websites, plug-ins and applications (including cookies, tracking technologies and widgets by third party advertisers), it is important that you understand that by clicking on those links or enabling those connections, you may allow third parties to collect or share data about you. Great Meera is not responsible for use of your Personal Information or Sensitive Personal Information by such third parties and it is advisable to read such third party’s privacy policy under which your data will be processed.

3. WHY WE COLLECT, USE AND STORE THE PERSONAL DATA

  1. Verification, Authentication and Processing of Application purposes:
    We process your Personal Information (including Sensitive Personal Information) for creating login credentials or establishing an account based relationship, doing KYC evaluation and risk assessments in order to authenticate and authorize your use of our products or services depending on if you are a merchant, consumer, borrower, service provider or business partner, and your choice of services or products. The type of Personal Information (including Sensitive Personal Information) typically required is Identification Information, Identity, and Account Log-In Information, Contact Information and Financial Information. This is necessary to fulfil our legal obligations under certain applicable laws of India. To provide product/s or service/s made available by Great Meera or the merchant or a third party service provider or in combination of all or any of the above.
     

  2. To do internal risk assessments and analysis
    We may process your Personal Information (including Sensitive Personal Information) for the purposes of risk assessments and evaluations including or KYC checks, to improve our services, reduce fraud rates, build risk models, etc. We may also share such analysis with our business partners who may rely on the same to make decisions regarding whether to offer their products or services to you. Such analysis as described above does not usually utilise any Sensitive Personal Information about you and mostly your Personal Information is used for these purposes.
     

  3. Collection of Personal Data for propagating business.
    From time to time, we may request aforementioned Personal Data from you to process your applications, and to get valuable feedback from your experience. In addition, we may also use your Personal Data for other business purposes or in order to help serve you better, such as informing you of new services, or alliances that could help you in your career or business. We will take reasonable steps to ensure that your Personal Data is accurate and complete. 
     

  4. Disclosure to third parties 
    We may disclose Personal Data to third parties. This disclosure may be required for us to check your eligibility for, provide you access to, and enable fulfilment of any services being provided to you, or to comply with any legal obligations, to enforce user agreements, to facilitate any marketing and advertising activities, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to any services being provided to you. You expressly consent and agree to such disclosures to third parties.
    We may disclose your personal information to third parties, such as business partners, service providers. This disclosure may be required for us to provide you access to our products and services; for enhancing your experience; for providing feedback on products; to collect payments from you; to comply with our legal obligations; to conduct market research or surveys; to enforce our Terms of Use; to facilitate our marketing and advertising activities; to analyse data; for customer service assistance; to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to our product and services. We do not disclose your personal information to third parties for their marketing and advertising purposes without your explicit consent. 

    We may disclose personal information if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal process. We may disclose personal information to law enforcement agencies, third party rights owners, or others in the good faith belief that such disclosure is reasonably necessary to enforce our Terms of Use or Privacy Policy; respond to claims that an advertisement, posting or other content violates the rights of a third party; or protect the rights, property or personal safety of our users or the general public. 

    We and our affiliates will share / sell some or all of your personal information with another business entity should we (or our assets) plan to merge with, or be acquired by that business entity, or re-organization, amalgamation, restructuring of business. Should such a transaction occur that other business entity (or the new combined entity) will be required to follow this Privacy Policy with respect to your personal information. 
     

  5. Collecting Personal Data for online surveys 
    At times, we conduct online surveys to better understand the needs and profile of our visitors. When we conduct a survey, we will inform you about how we will use the Personal Data prior to your taking the survey. If you do not want to participate in the survey, you may refrain from contributing to it at your own discretion. 
     

  6. Use of cookies 
    The Company tracks information provided by visitor’s browser, including the website the visitor came from (known as the referring URL), the type of browser used and other information that does not personally identify any visitor of the GREAT MEERA’s website. This may include installation of cookies and collection of other session data. 
     

  7. IP address
    The GREAT MEERA website uses Internet Protocol (IP) Addresses. An IP Address is a number assigned to your computer by your Internet service provider so you can access the Internet. Generally, an IP address changes each time you connect to the Internet (it is a “dynamic” address). We use your IP address to report aggregate information on use and to help improve our services. 
     

  8.  To protect our business and to ensure compliance with the law
    We process your Personal Information (including Sensitive Personal Information) to meet the requirements of applicable laws, regulations, standards, rules, codes and the requirements as may be applicable on non-banking financial institutions and other codes with which We must comply. This includes:

    1. authenticating and validating your access to your account or to mitigate and protect against identity theft or fraud. To do this, some of your Personal Information (including Sensitive Personal Information) and non-Personal Information may be collected by us or these may be directly or indirectly delivered to us by merchants, group companies or other business partners. We  will use this Personal Information (including Sensitive Personal Information) for the purpose of anti-fraud systems and this may be retained by us for our future use for reference and cross-reference of information;

    2. consulting and reporting your Personal Information (including Sensitive Personal Information) and behaviour on monetary obligations to legitimately constituted financial, commercial or service risk centres, or to other financial institutions, under applicable laws of India or in furtherance to contracts;

    3. verifying your identity and comparing your Personal Information (including Sensitive Personal Information) to verify accuracy for reporting obligations under applicable laws or payment scheme rules or KYC norms;

    4. processing your information for the purpose of ensuring compliance under applicable laws and for resolving or contesting any claims made by or against you against us or our group companies, our business partners or any other third party;

    5. processing or using your Personal Information (including Sensitive Personal Information) if you exert your right of refusal for any of our services or any services provided by us or our group companies, our business partners or any other third party; and

    6. processing (including storing or using) your Personal Information (including Sensitive Personal Information) to ensure business continuity of our businesses and appropriate disaster recovery for the Websites and Platforms, services and products.

4. HOW WE USE YOUR INFORMATION

We use the information we collect to operate, improve, and protect the services we provide, and to develop new services. For example, we use your information to: 

  1. provide GREAT MEERA’s Services; 

  2.  improve, modify, add to, or further develop GREAT MEERA’s services; 

  3. protect you, GREAT MEERA’s service providers, or GREAT MEERA from fraud, malicious activity, or other privacy and security-related concerns 

  4. provide customer service to you 

  5. investigate any misuse of GREAT MEERA’s Services; and 

  6. develop new services. 

  7. connect with you and assist you 

  8. provide merchants with statistical insights and reports

5. OUR STEPS TO PROTECT YOUR INFORMATION

  1. The security of your Personal Information and Sensitive Personal Information is important to us. We take steps designed to protect your information that we collect, maintain, or disclose. These steps include maintaining information security controls, such as encryption technologies when transferring data or even when storing data, firewalls, and controls over the physical access to our systems. We regularly evaluate the security controls that we use, as well as the controls that our service providers use, for protecting the security and confidentiality of your information. Our goal is to maintain effective security controls, as measured by relevant industry standards or by independent security auditors, for all of the ways that you can use GREAT MEERA’s Services. We take all measures to to prevent alteration, loss or fraudulent or unauthorized access of your Personal Information (including Sensitive Personal Information). We have put in place procedures to deal with breach of Personal Information and will notify you and any applicable regulator or authority of a breach where we are legally required to do so.
     

  2. GREAT MEERA may keep your information for as long as necessary to fulfil the purpose for the information is collected. In addition, for some types of your information, GREAT MEERA may apply a longer retention period, such as for research or statistical analyses, except when storing or using that information for longer periods of time is not permitted under applicable law. As permitted under applicable law, even after you stop using the GREAT MEERA’s services or terminate your account with GREAT MEERA, we may retain your information. 

6. Your Consent to Great Meera to share/ process/ use and store your Personal Information

We process Sensitive Personal Information only when we have obtained your consent in manner provided hereinunder. For collecting, processing (including using and storing), disclosing or sharing your Sensitive Personal Information as described in this Policy, we hereby through this Policy, seek your consent and give you a notice regarding collecting, processing (including using and storing), and sharing your Sensitive Personal Information for one or more of the purposes detailed herein. For any purposes, where, as per applicable laws of India, a specific consent is required, we will seek such specific consent from you from time to time. In relation to information obtained from third parties or group entities, we rely on the consent taken herein in our favour for us to process the information. You may, of course, decline to share certain information with us, in which case we may not be able to provide to you some or all of the features and functionalities of the Websites and the Platform. This may also affect our ability to process your Personal Information (including Sensitive Personal Information) and may therefore lead to the non-availability or discontinuation of the services for which such Personal Information (including Sensitive Personal Information) are to be used or was being used, at our sole discretion. In line with the mandate of the RBI, the Company has adopted and implemented the following requirements:

  1. The Company shall ensure that LSPs/DLAs engaged by them do not store personal information of the customers except some basic minimal data (viz., name, address, contact details of the customer, etc.) that may be required to carry out their operations.

  2. The Company shall carry out the responsibility of ensuring that the LSPs and DLAs maintain data privacy and security of the customer’s personal information.

  3. The Company shall be provided with an option to give or deny consent for use of specific data, restrict disclosure to third parties, data retention, revoke consent already granted to collect personal data and if required, make the app delete/ forget the data.

  4. The Company shall ensure that any collection of data by their DLAs and DLAs of their LSPs is need-based and with prior and explicit consent of the customers having an audit trail. The Company shall also ensure that DLAs desist from accessing mobile phone resources like file and media, contact list, call logs, telephony functions, etc.

  5. The Company shall ensure that the customer shall be provided with an option to give or deny consent for use of specific data, restrict disclosure to third parties, data retention, revoke consent already granted to collect personal data and if required, make the app delete/ forget the data.

  6. The purpose of obtaining customers’ consent needs to be disclosed at each stage of interface with the customers.

  7. Explicit consent of the customer shall be taken before sharing personal information with any third party, except for cases where such sharing is required as per statutory or regulatory requirement.

  8. The Company shall ensure that clear policy guidelines regarding the storage of customer data including the type of data that can be stored, the length of time for which data can be stored, restrictions on the use of data, data destruction protocol, standards for handling security breach, etc., are put in place and also disclosed by DLAs of the REs and of the LSP engaged by the Company prominently on their website and the apps at all times.

  9. The Company shall ensure that no biometric data is stored/ collected in the systems associated with the DLA of the Company / their LSPs, unless allowed under extant statutory guidelines.

  10. The Company shall ensure that they and the LSPs engaged by them comply with various technology standards/ requirements on cybersecurity stipulated by RBI and other agencies, or as may be specified from time to time, for undertaking digital lending.

  11. All data (including personal data and information of the customers) shall be stored in India.

  12. No information (including personal information or data of the borrowers) shall be collected by LSPs/ DLAs without the prior explicit consent of the customers. Nothing stated above shall preclude the Company from adhere to the mandate of disclosing / reports borrowers to the credit information companies in accordance with the Digital Lending Guidelines and/or the Outsourcing Policies and/or other extant instructions / guidelines / directions / circulars of the RBI

7. OUR RIGHTS TO DISCLOSE YOUR INFORMATION

GREAT MEERA makes various types of disclosures of your information to other persons as permitted by law. Our disclosures of your information may apply to some or all of the categories of your information that we collect. For example, GREAT MEERA may disclose all of the types of your information      consistent with your consent or instruction. GREAT MEERA also discloses, or reserves the right to disclose, your information: 

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  1. With GREAT MEERA’s service providers or contractors in connection with the services they perform for GREAT MEERA; 

  2. To the extent permitted by law, it will be necessary for us to verify the details you have supplied. Such verification could be done through third party service providers, who shall be bound by the obligation of confidentiality and data protection. 

  3. If GREAT MEERA believes in good faith that disclosure is appropriate to comply with applicable law, regulation, or legal process (such as a court order or subpoena); 

  4. In connection with a change in ownership or control of all or a part of GREAT MEERA’s business (such as a merger, acquisition, or bankruptcy); 

  5. Between and among GREAT MEERA and GREAT MEERA’s future affiliates (such as subsidiaries or other companies under common control or ownership); or 

  6. With your consent (by any reasonable method, including when you orally give your consent), unless you timely revoke your consent. 

  7. We may collect, use, process, or disclose your information in an aggregated or anonymized manner (i.e., in a manner that does not identify you personally) for any purpose permitted under applicable law. 

  8. As a convenience to our visitors, this GREAT MEERA website may contain links to a number of sites that we believe may offer useful information. The policies and procedures we described here may not apply to those sites. We suggest contacting those sites directly for information on their privacy, security, data collection, and distribution policies. 

  9. We will process, disclose or share your Personal Data only if required to do so by law or in good faith belief that such action is necessary to comply with our contractual obligations, legal requirements or legal process served on us. 

8. WITHDRAWAL OF CONSENT

If you change your mind after opting-in, you may withdraw your consent to contact you, for the continued collection, use or disclosure of your information, at any time, by mailing us at support@greatmeera.in. 

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However, if you have availed any of our services, we shall have the right to continue processing your information till such engagement persists. However, we shall not retain your data and information if it is no longer required by us and there is no legal requirement to retain the same. Do note that multiple legal bases may exist in parallel and we may still have to retain certain data and information at any time.

9. RIGHT TO RECTIFICATION

In the event that any personal data provided by you is inaccurate, incomplete or outdated then you shall have the right to provide us with the accurate, complete and up to date data and have us rectify such data at our end immediately. We urge you to ensure that you always provide us with accurate and correct information/data to ensure your use of our services is uninterrupted.

10. CONTACTING GREAT MEERA

If you have any question about this Privacy Policy or wish to contact us for any reason in relation to the Personal Data processing, please contact us by mailing /write to us at support@greatmeera.in.  

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