Last updated: June 19, 2023
We, at Lorien Business Management Private Ltd (“Company”) and our affiliated companies, are committed to respecting your online privacy and recognize your need for appropriate protection and management of personally identifiable information ("Personal Information") you share with us, in-line with the applicable data protection laws and regulations.
If you do not agree to this Policy or any part thereof, please do not use or access Our Platform or any part thereof. We reserve the right to change this Policy without prior notice. We encourage you to regularly review this policy to ensure that you are aware of any changes and how your personal data may be used.
As defined by law, Personal Information (PI) - means any information relating to an identified or identifiable living person. In particular using a common identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person or any other piece of information as per applicable laws and regulations.
We are committed to safeguarding your privacy and ensuring that you continue to trust us with your personal data. When you interact with us you may share personal information with us which allows identification of you as an individual.
b) This document is an electronic record as per laws and amended provisions pertaining to electronic records in various statutes as applicable on Us. This electronic record is generated by a computer system and does not require any physical or digital signatures.
INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT:
When you use our App, we collect and store your information (personal information) which is provided by you from time to time by explicitly seeking permissions from you to get the required information. Our primary goal in doing so is to provide you a safe, efficient, smooth, and customized experience and services. This allows us to provide services and features that meets your needs, and to customize Our Platform to make your experience safer and easier and to improve the services provided by us. More importantly, we collect personal information from you that we consider necessary for achieving the aforementioned purpose.
In general, you can browse the Platform without telling us who you are or revealing any personal information about yourself. However, to create an account on the Website or App, you must provide us with the certain basic information required to provide customized services. The information we collect from you, inter alia, includes:
You ensure that all information you provide to Us is accurate, true, correct, authentic.
We collect information about you or your usage to provide better services to all our users. Information we may collect from you and third parties is Information:
● that personally identifies you (for example, your name, address, email address, telephone number, social security number or other government-issued identification numbers, static Internet Protocol (“IP”) address, mobile device ID, geo-location information, and employment information;
● that can personally identify you if linked with other information (for example, your country of citizenship, graduation date, and other education information); and
● about your computer, mobile device, Internet connection, and usage of this Platform.
You might have questions about how and why we collect this information. We collect information in the following ways:
● Many of our services require you to register/sign up for an account on Our Platform. When you do, we will ask for personal information, such as but not limited to your name, email address, and telephone number to create/update your account.
● To provide you additional services, we may collect your profile information such as, but not limited to educational background, work experience, date of birth.
● We collect information about the services that you use and how you use them such as, but not limited to log information and location information.
● We may collect your personal information such as but not limited to bank details, passport details to assist for study abroad program which includes services like Letter of recommendation, student profile, student visa, and application to university programs.
● When you communicate with Us or use Our Platform to communicate with other Members (such as advertisers, colleges/ institutes, etc.), we collect information about your communication and any other additional information you choose to provide.
Consent: We collect this information:
● when you actually provide it to us.
● automatically as you use Our Platform (Website or mobile application).
● from third parties, such as when you log in using a LinkedIn/Social Media account.
HOW CAN YOU ACCESS AND CORRECT YOUR INFORMATION
You can review and change your personal information and visit your account profile page.
You may also contact us at email@example.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
SHARING YOUR INFORMATION
We may share information from or about you with:
● Our subsidiaries and affiliates.
● Partners and service providers who help us prevent fraud, collect bills, service loans, process payments, market our business, store data, and jointly offer or refer financial products and services to you. We require that these third parties use information from or about you only so they can perform the services you or we ask them to.
● Third-party services, such as LinkedIn, if you connect your loan application to their accounts. We may use the information to inform your application.
● Credit bureaus to report account information, as permitted by law.
● Law enforcement and government officials when: we are compelled to do so by court order, subpoena, search warrants, or similar legal procedure; we need to do so to comply with law; or if we believe in good faith that sharing your personal information is necessary to combat fraud, prevent physical harm or financial loss, or to report suspected illegal activity.
LINK TO THIRD-PARTY
● Our Platform has a link to a registered third party which collects data on our behalf and data is stored to a secured server to perform a credit risk assessment. We ensure that our third-party service provider takes extensive security measures in order to protect your personal information against loss, misuse or alteration of the data as has been represented by them to Us.
● Our third-party service provider employs separation of environments and segregation of duties and have strict role-based access control on a documented, authorized, need-to-use basis. The stored data is protected and stored by Platform-level encryption. They enforce key management services to limit access to data.
● Furthermore, We also get hosting security from third party service providers – they represent to us that they use industry-leading anti-virus, anti-malware, intrusion prevention systems, intrusion detection systems, file integrity monitoring, and Platform control solutions.
YOUR RIGHTS AS A USER
The information you provide Us with, will be used only for the purpose for which you provided it. You may access and correct PII by signing into your account and updating your account information. Additionally, a user may access and amend their information by calling one of the contact centres listed in our “Contact Us” sections indicated below.
HOW DO WE USE THE INFORMATION YOU SHARE WITH US
We use your information to:
● make sure that you are over the age of 18;
● verify your identity, the accuracy of your information, and guard against potential fraud;
● determine if you qualify for our services
● let our partners service you; and
● communicate with you during and after the service process.
We may also use your information to:
● improve our services;
● offer products and services to you from us or third parties that we think you’d be interested in;
● provide customer support;
● offer you search results and ads more tailored to you;
● let you know about changes to our Website or other products and services;
● enforce agreements that you have made with us;
● protect against fraud;
● implement servicing activities;
● implement collection activities as needed;
● evaluate and/or improve marketing and advertising campaigns;
● comply with any court order, law or legal process; and/or
● improve our Website and mobile application/ Platform.
We may process your Personal Information for the following purposes:
We use information collected from cookies and other technologies, like pixel tags, to improve your user experience and the overall quality of our services. When showing you tailored ads, we will not associate an identifier from cookies or similar technologies with sensitive categories, such as those based on race, religion, sexual orientation or health.
Our automated systems analyse your content to provide you customised search results, recommendations and specific promotions and offers
Send alerts and newsletter(s) to you (Provided you subscribe to the same. To unsubscribe, please visit your account settings)
Improving our website and its content to provide better features and services
Conducting market research and surveys with the aim of improving our products and services.
Sending you information about our products and services for marketing purposes and promotions.
Preventing, detecting, investigating and prosecuting crimes (including but not limited to fraud and other financial crimes) in any jurisdiction, identity verification, government sanctions screening and due diligence checks
Establishing, exercising or defending legal rights in connection with legal proceedings (including any prospective legal proceedings) and seeking professional or legal advice in relation to such legal proceedings.
HOW DO THIRD PARTIES USE THE INFORMATION YOU SHARE
Cookies and Other Tracking Technologies: Some part of our Platform utilize "cookies" and other tracking technologies. A "cookie" is a small text file that may be used, for example, to collect your information about Website activity. Some cookies and other technologies may serve to recall Personal Information previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. Blocking cookies may affect your access to the service.
Third-Party Services: We do not intend to transfer Personal Information without your consent to third parties unless such transfer is required for providing relevant services or for purposes legal purposes. When you are in a relationship with Us, your personal information may be transferred to geographies outside India, for the purposes mentioned in this policy or to their local service providers for support in the pursuance of such purposes. Transfers outside India are covered by standard data protection laws.
We make no representations or warranties regarding how your information is stored or used on third-party servers. We recommend that you review the privacy statement of each third-party site linked from Our Site to determine their use of your personal information.
HOW DO WE DEAL WITH INFORMATION BELONGING TO CHILDREN
We do not enter into an agreement with children or minors. To use the Site you agree that you must be of minimum age (described in this paragraph below) or older.
In case you are resident of the European Union, the minimum age for these purposes shall be 16, however, if local laws require that you must be older in order for Us to lawfully provide the services on the Platform to you then that older age shall apply as the applicable minimum age.
In all jurisdictions outside the European Union, if you are under the age of 18 or the age of majority in your jurisdiction, you must use Our Platform under the supervision of your parent, legal guardian or responsible adult.
HOW DO WE SHARE YOUR INFORMATION
We restrict access to your Personal Information to employees who we believe reasonably need to know/or that information in order to fulfill their jobs to provide, operate, develop, or improve our products or services.
We do not rent, sell, or share personal information about you with other people or non-affiliated companies except:
1. to provide products or services you've requested,
2. when we have your permission to do so,
3. or under the following circumstances:
● We provide the information to trusted partners under confidentiality agreements. These companies may use your personal information to help Us communicate with you about offers from Us and our marketing partners. However, these companies do not have any independent right to share this information.
● We respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims;
● We transfer information about you if We are acquired by or merged with another company.
● We share your personal information with colleges or educational institutions, etc. based on your browsing behaviour or expression of interest regarding courses, specializations and institutions or in case of applications for admission to such colleges or educational institutions, who may further contact you and process your information for the said purposes.
Advertisements by Third Party Advertisers: We display targeted advertisements based on personal information. We do not provide any personal information to the advertiser when you interact with or view a targeted ad. However, by interacting with an ad you are consenting to the possibility that the advertiser will make the assumption that you meet the targeting criteria used to display the ad.
We work with vendors, partners, advertisers, and other service providers in different industries and categories of business.
HOW LONG DO WE RETAIN YOUR INFORMATION
Your personal information processed by Us are kept in a form that permits your identification for no longer than is necessary for the purposes for which the personal information are processed in line with legal, regulatory, contractual or statutory obligations as applicable.
At the expiry of such periods, your personal information will be archived to comply with legal/contractual retention obligations or in accordance with applicable statutory limitation periods.
To the extent permitted by law, We may record and monitor your communications with us to ensure compliance with our legal and regulatory obligations and our internal policies. This may include the recording of telephone conversations.
You may have the right to invoke certain rights (as per applicable laws and regulations such as GDPR) in relation to your personal information being processed by the Platform.
The Platform may be allowed by law, in particular in case of excessive or manifestly unfounded request, to charge a fee for fulfilling your request, subject to applicable conditions.
You are legally entitled to request details of the personal information we may be holding about you. We provide you the ability to keep your personal information accurate and up-to-date. If at any time you would like to rectify, erase or restrict the processing of your personal information, or you would like to obtain confirmation whether or not your personal information is processed by it, access your personal information, exercise your right to data portability or withdraw your consent to the processing, please contact us.
You are entitled to lodge a complaint with a competent Data Protection Authority where existing, concerning the Platform’s compliance with the applicable data protection laws and regulation.
HOW WE PROTECT YOUR INFORMATION
We aim to make sure your information is safe and to protect you against fraud. Only authorized employees can access your information, and only after they verify their identity. We do not store your personal information on our company systems. Instead, your personal information is stored in data centers that are protected by physical, electronic, and procedural safeguards.
The Platform intends to protect your personal information and to maintain its accuracy as confirmed by you. We implement reasonable physical, administrative and technical safeguards to help us protect your personal information from unauthorized access, use and disclosure. For example, we encrypt all sensitive personal information when we transmit such information over the internet. We also require that our registered third-party service providers protect such information from unauthorized access, use and disclosure.
We have stringent security measures in place to protect the loss, misuse and alteration of information under control. We Endeavour to safeguard and ensure the security of the information provided by you. We use Secure Sockets Layers (SSL) based encryption, for the transmission of the information, which is currently the required level of encryption in India as per the law.
We blend security at multiple steps within our products with state-of-the-art technology to ensure our systems maintain strong security measures and the overall data and privacy security design allow us to defend our systems ranging from low hanging issues up to sophisticated attacks.
The security and confidentiality of your Personal Data is important to us and We have invested significant resources to protect the safekeeping and confidentiality of your personal data. When using external service providers acting as processors, we require that they adhere to the same standards as Ours. Regardless of where your personal information is transferred or stored, we take all steps reasonably necessary to ensure that personal data is kept secure.
The Platform is built with strict security features that continuously protects your information.
Our Platform has stringent security measures in place to protect the loss, misuse and alteration of information under control. We Endeavour to safeguard and ensure the security of the information provided by you. We use Secure Sockets Layers (SSL) based encryption, for the transmission of the information, which is currently the permitted level of encryption in India. When the information provided by you is not transmitted through this encryption, your system (if configured accordingly) will display an appropriate message ensuring the best level of secrecy for your information. We work hard to protect from unauthorized access, alteration, disclosure or destruction of information we hold, including:
● We use encryption to keep your data private while in transit;
● We review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems;
● We restrict access to personal information to our employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
● We have physical, electronic, and procedural safeguards that comply with the laws prevalent in India to protect personal information about you.
● We build security into our Services to protect your information.
HOW CAN YOU DELETE YOUR INFORMATION OR ALTER INSTRUCTIONS TO US
To delete your information, you can:
a) Delete/Uninstall our App: This may prevent us from collecting your information from your device periodically but your information will be retained by Us.
b) Reach out to Us: Reach out to Us if you wish to delete your information from our servers.
To stop receiving promotional emails, follow the instructions in any promotional message you receive from Us. Even if you opt-out of getting marketing messages, we may still send you transactional messages, including responses to your questions or information about your application or loan.
If you do not want us or third parties to automatically collect information from you through your use of the Platform in the ways described above, do not download the Platform or delete it from your device and write to us stating the same.
DISCLOSURE OF PERSONAL AND FINANCIAL INFORMATION
We may be required to disclose the User’s personal and financial information to the statutory authorities in connection with any legal process that may be initiated by such authorities in accordance with applicable laws.
It is possible that we may need to disclose personal information when required by law, such as responses to civil or criminal subpoenas, or other requests by law enforcement personnel. We will disclose such information wherein we have a good faith/ belief that it is necessary to comply with a court order, ongoing judicial proceeding, subpoena, or other legal processes, or to exercise our legal rights or defend against legal claims
It may become necessary for Us to disclose User’s personal information to its agents and contractors in the course of normal business operations. However, these parties would be required to use the information obtained from Us for such purposes exclusively. We will endeavor to take all reasonable steps to ensure that the confidentiality of customer information is maintained by imposing strict confidentiality standards on all the third parties to whom it discloses such information
We may use the personal information that you have shared during the process of registration or otherwise for verification purposes and the user/ customer agrees and allows Us to share such information with third parties solely for verification purposes, credit reference companies and with government agencies, including but not limited to the Reserve Bank of India (“RBI”) for the cause of an inspection or any other legal diligences which may be conducted by it. We may also use the information you provide to update our consumer credit database.
Personal information may be transferred to any group company of Company at any time or to a third party as a result of a sale, acquisition, merger, reorganization or other change in control. If Company is sold, merged or transferred then part of the sale may include your personal information
We operate channels, pages and accounts on some social media sites (“Social Media Properties”) to inform, assist and engage with you. These Social Media Properties should be considered to be an extension of Us. We monitor and record comments and posts made on these channels in order to improve Our products and services. Please note that you must not communicate with Us through such social media sites the following information:
● Personal Information as defined above;
● Sensitive personal data including (i) special categories of personal data meaning any information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation and (ii) other sensitive personal data such as criminal convictions and offences and national identification number ;
● Excessive, inappropriate, offensive or insulting information towards individuals.
We are not responsible for any information posted on those sites other than the information posted by Our employees on Our behalf. We are only responsible for Our own use of the personal data received through such sites.
We shall not be liable for any loss or damage sustained by reason of any disclosure (inadvertent or otherwise) of any information concerning the user's account and / or information relating to or regarding online transactions using credit cards / debit cards and / or their verification process and particulars nor for any error, omission or inaccuracy with respect to any information so disclosed and used whether or not in pursuance of a legal process or otherwise. We do not store any Credit / Debit card details.
Any other personal information shared by you which is not asked by Us during registration, either mandatorily or optionally; accounts to wilful and intentional furnishing; and We will not be liable for breach of such information.
While using Our Platform, You agree not to, by any means (including hacking, cracking or defacing any portion of the Platform) indulge in illegal or unauthorized activities including the following:
- Restrict or inhibit any authorized user from using Our Platform;
- Use Our Platform for unlawful purposes;
- Harvest or collect information about the Platform users without their express consent;
- "Frame" or "mirror" any part of the Platform without our prior authorization;
- Engage in spamming or flooding
- Transmit any software or other materials that contain any virus, time bomb, or other harmful or disruptive components;
- Remove any copyright, trademark or other proprietary rights, notices contained in the Platform;
- Use any device, application or process to retrieve, index, "data mine" or in any way reproduce or circumvent the navigational structure or presentation of the Platform; or
- Permit or help anyone without access to Platform, to use Platform through your username and password or otherwise.