Privacy Policy

At Sammaan Finserve Limited (formerly known as Indiabulls Commercial Credit Limited) (hereinafter referred to as “Sammaan Finserve” “we”, “us”, etc.), a company incorporated under the provisions of Companies Act, 1956, having our registered office at Sammaan Finserve Limited, 2nd Floor, Plot No-3, Block-A, Pocket-2, Sector-17, Dwarka Residential Scheme, Dwarka, New Delhi - 110075,and having corporate identity number U65923DL2006PLC150632, we value your trust and respect your right to privacy.

Sammaan Finserve is committed to treating data privacy seriously. This Privacy Policy provides you with details about the manner in which your data is collected, stored and used by us. You are advised to read this Privacy Policy carefully. If you do not agree to the terms of this Privacy Policy, please do not further use or access Sammaan Finserve website or Sammaan Finserve applications. By using Sammaan Finserve mobile app/website or its services, you consent to collection, storage, use, transfer, share and distribute the personal information, which you provide (including any changes thereto as provided by you) for any of the services that Sammaan Finserve offer.

General
This privacy statement is applicable to website and applications (mobile and hybrid, hereinafter referred to “applications”) of Sammaan Finserve. This Privacy Policy applies regardless of whether you use a computer, mobile phone, tablet, or television or any other media or computer resource to access our Services. It also applies to those who register on our website/applications in connection with use of our services, or whose data Sammaan Finserve otherwise receives in connection with its services. It is important that you read the Privacy Policy carefully because whenever you use our website/ applications; your personal data will be processed (if at all) in accordance with this policy.

Data Privacy and Protection Strategy

1) Data Privacy Principles

The processing of personal data by Sammaan Finserve shall adhere to the following principles

1.1 Lawfulness, fairness, and transparency

Sammaan Finserve must process personal data in a lawful, fair, and transparent manner that upholds individuals' rights. Before starting any personal data processing activity, Sammaan Finserve needs to identify and establish the legal basis for the processing. Sammaan Finserve must verify that this basis is in line with regulatory requirements to ensure that the appropriate option is selected from those available. Personal data will only be obtained, processed, or stored when all requirements have been met. These requirements include:

a. Obtaining the data principal's explicit consent for processing their personal data for one or more specific purposes.
b. Processing is necessary for the performance of a contract to which the data principal is a party or to take steps at the request of the data principal prior to entering into a contract.
c. Processing is necessary for compliance with a legal obligation of Sammaan Finserve.
d. Processing is necessary to protect the vital interests of the data principal or of another natural person.
e. Processing is carried out for the performance of a task that is carried out in the public interest or by official authority vested in the organization.
f. Processing is necessary for the purposes of the legitimate interests pursued by Sammaan Finserve or by a third party, unless such interests are overridden by the fundamental rights and freedoms of the data principal that require protection of personal data, particularly when the data principal is a child.
At all times, we take the processing of personal data seriously and ensure that we have legitimate grounds for such processing.

1.2 Purpose Limitation
To ensure security and privacy, personal data shall be collected only for specified, explicit, and legitimate purposes, and will not be subsequently processed in a way that is incompatible with those purposes. Sammaan Finserve will process personal data only for the original purpose it was collected. To complete the processing, personal data may be shared with employees, affiliates, and other vendors. Adequate technical and organizational measures are in place to protect the personal data. If Sammaan Finserve intends to process personal data for other purposes than those for which it was initially collected, they shall seek specific consent from the data principals prior to such processing.

1.3 Data minimization
Sammaan Finserve shall collect only the amount of personal data that is necessary, relevant, and limited to the processing requirement. The systems, employees, processes, and activities of Sammaan Finserve are designed to limit the collection of personal information to what is directly relevant and necessary to fulfil the specified purpose.

1.4 Storage limitation
Personal data shall be stored in an identifiable form for a period necessary for processing purposes. Sammaan Finserve will follow defined procedures to ensure compliance with retention periods specified by relevant laws, contracts, and business requirements. Any disposal of personal data will prioritize the protection of data principals' rights and privacy using secure methods such as confidential waste disposal, shredding, secure electronic deletion or hard drive destruction.

1.5 Integrity and confidentiality (security)


Personal data is processed in a way that assures adequate security, which includes protecting against unauthorized or unlawful processing, accidental loss, destruction, or damage through technical or organizational measures. Sammaan Finserve shall have appropriate security measures in place to prevent accidental, deliberate compromise, or unauthorized access to the personal data. These measures involve not only information security, i.e., network and information systems protection but also include physical and organizational security

1.6 Accountability
Organizations must demonstrate their compliance with data protection laws and principles by being accountable and showing how they adhere to these principles. The organizations must also provide details and a summary of the measures and controls in place to safeguard personal data and mitigate processing risks. Sammaan Finserve will frequently conduct risk assessments and information audits to identify, assess, measure, and monitor the impact of personal data processing. Sammaan Finserve will also adopt suitable and sufficient technical and organizational measures to ensure that personal data is protected, and data protection laws are adhered to. These measures may be documented, and Sammaan Finserve can furnish evidence of their effectiveness.

Personal Data and its collection
Sammaan Finserve must process personal data in a lawful, fair, and transparent manner that upholds individuals' rights. Before starting any personal data processing activity, Sammaan Finserve needs to identify and establish the legal basis for the processing. Sammaan Finserve must verify that this basis is in line with regulatory requirements to ensure that the appropriate option is selected from those available. Personal data will only be obtained, processed, or stored when all requirements have been met. These requirements include:
Personal Data, means and includes, any data relating to identified or identifiable living person (‘data subject’ here in referred as you/your’) including but not limited to, name, address, mailing address, telephone number, email ID, bank account details including details linked to credit/debit payment instruments, information about mobile phone, any personal details that may have been voluntarily provided by the customer, whether to Unique Identification Authority of India (UIDAI), Credit Information Bureau of India Limited (CIBIL) or any other regulated agency including but not limited to any other Credit Information Companies (CIC).

1. Information Collected when you use our Website
We collect data about you or your usage to provide better services to all of our users. We collect data in the following ways: -
• Many of our services require you to register/sign up for an account on SFL. When you do, we will ask for Personal Data, such as, but not limited to your name, email address, contact number, country, address to create/ update your account.
• When you use the SFL website to request a call back or more information or more assistance or to apply for new loans, we will ask for Personal Data including but not limited to Name, Email ID and Contact number.
• We may collect your personal data such as but not limited to financial details-bank statement, salary statement, family details-father, mother, spouse name for compliance requirement purposes.
• When you use the SFL website to provide feedback, we collect your Personal Data including but not limited to name, title, Email ID, contact number, address and country.
• We collect data about the services that you use and how you use them. This data includes log data and location data.
• We may collect your data through campaigns and publicly available sources.
• When you communicate with SFL or use the SFL platform to communicate with other members, we collect data about your communication and any data you choose to provide. If you choose to sign in with your social media account to access Sammaan Finserve, or otherwise connect your social media account with the services of Sammaan Finserve, you consent to our collection, storage, and use, in accordance with this Privacy Policy, of the data that you make available to us through the social media interface. Please see your social media provider's privacy policy and help center for more information about how they share data when you choose to connect your account.
• Data collected during credit assessment/appraisal of loan, risk assessment, fraud checks, fraud detections, processes undertaken for fraud prevention, detecting malpractices or discrepant documents or information, prevention of misuse, assessment of credit worthiness, evaluation of financial standing, due diligence including but not limited to legal and technical checks, background check and verification , physical and other inspections, verifications, KYC/ Anti Money Laundering (AML) checks, monitoring, collections, recovery, customer service etc.
• From any persons involved in any payment system or infrastructure or architecture of which Sammaan Finserve is a part including National Automated Clearing House (NACH), UPI, Electronic Clearing Service (ECS), , Immediate Payment Service (IMPS), Real Time Gross Settlement (RTGS), National Electronic Fund Transfer (NEFT) etc., or from any persons (including TPAP) to whom the Sammaan Finserve acts as a service provider, distributor, agent, referral entity, promoter, marketer, sponsor bank, PSP bank, trustee, etc., where you are part of any payment or withdrawal or transaction or purchase/ sale/ distribution of any Product, whether as payee, payer, beneficiary, intermediary, distributor etc. and whether your interface/ interaction is directly with us or not or with any such other person or any platform/app.

2. Information Collected when you use our Applications
When you download our mobile application or use our hybrid application (related to our various services) we collect the below information, but not limited to –Email ID, Name, Address Country/City, Mobile Number. Sammaan Finserve does not collect Personal Data about individuals except when such individuals specifically provide such data on a voluntarybasis. Upon such voluntary disclosure of Personal Data, we may further verify, collate or receive data about you from publicly and commercially available sources (as permitted by law), which we may combine with other data we receive from you. We may also receive data about you from third-party social networking services if you are already connected with those services.

Lawful Basis of Processing
We may process your data because: We have a contract with you would have given us express permission to do so. We must have provided services to you after you have purchased something from us. We must have provided services to you because you have availed for one of our offers to comply with the law.

Use of Personal Data
We use Personal Data to provide you with loan you explicitly requested for, to resolve disputes, troubleshoot concerns, help promote safe services, assess your interest in our services, inform you about offers, products, services, updates, customize your experience, detect and protect us against errors, fraud and other criminal activity, enforce our terms and conditions, etc.

We may also use your Personal Data to send you offers regarding various services/facilities which Sammaan Finserve or its group companies may, from time to time, launch. Your consent will be taken before we send you any such communication.

We may occasionally ask you to complete optional online surveys. These surveys may ask you for contact information and demographic information (like zip code, age, gender, etc.). We use this data to customize your experience at Sammaan Finserve. Since the surveys will be optional, any personal data you provide will be voluntarily given by you. All such data shall be transmitted and stored by us in an encrypted manner in accordance with all applicable laws to ensure the secrecy and confidentiality of the personal data and such personal data shall not be shared or used except as contemplated herein.

Non-Personal Information
We may collect non-personal data such as:
• Device information (model, OS version, etc.)
• App usage data (features accessed, session duration)
• IP address
• Cookies and tracking technologies

Cookies and Other Tracking Technologies
Some of our Web pages utilize "cookies" and other tracking technologies. A "cookie" is a small text file that may be used, for example, to collect data about Web site activity. Some cookies and other technologies may serve to recall Personal Data previously indicated by a Web 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, but please note that if you choose to erase or block your cookies, you will need to re-enter your original user ID and password to gain access to certain parts of the Web site.
Tracking technologies may record data such as Internet domain and host names; Internet protocol (IP) addresses; browser software and operating system types; clickstream patterns; and dates and times that our site/application is accessed. Our use of cookies and other tracking technologies allows us to improve our website/applications and your Web experience. We may also analyse information that does not contain Personal Data for trends and statistics.
For more information about our use of cookies please refer to our Cookie Policy

Information Sharing and Disclosure
We restrict access to your Personal Data to employees who we believe reasonably need to know that data in order to fulfil their jobs to provide, operate, develop, or improve our products or services.
Sammaan Finserve does not rent, sell, or share Personal Data about you with other people or non-affiliated companies except: to provide products or services you've requested, when we have your permission, or under the following circumstances: We provide the data to trusted partners who work on behalf of or with Sammaan Finserve under confidentiality agreements. These companies may use your Personal Data to help Sammaan Finserve communicate with you about offers from Sammaan Finserve and our marketing partners. However, these companies do not have any independent right to share this data.

We may share data to Credit information companies, bureaus, fintech entities, Central KYC Records Registry, or service providers for the purposes of obtaining any reports, credit scores, credit information, scrubs, financial standing, fraud check, fraud probability, reference checks, due diligence, inspections, risk analysis etc.

We may share data and information with our co-lending partners, co-originators, collaborators, and persons with whom we may have a tie-up. Further list of co-lending partners is updated in our website from time to time.

We may share data with any persons involved in any payment system or infrastructure or architecture of which Sammaan Finserve is a part including NACH, UPI, ECS, , IMPS, RTGS, NEFT etc. or with any persons (including TPAP) to whom we acts as a service provider, distributor, agent, referral entity, promoter, marketer, sponsor bank, PSP bank, trustee, etc. where you are part of any payment or withdrawal or transaction or purchase/ sale/ distribution of any Product, whether as payee, payer, beneficiary, intermediary, distributor etc. and whether your interface/ interaction is directly with us or not or with any such other person or any platform/app.

We may disclose your personal data to agents or contractors of Sammaan Finserve and/or its group companies/affiliates to enable processing of transactions or communications with you “on need” basis. Your aforesaid data may be further used for assessment and analysis of our market, customers, products, and services and to understand the way people use our Services so that we can improve them and develop new products and services. However, it shall be on the basis that the agents are required to keep the data confidential and will not use the data for any other purpose other than to carry out the services they are performing for Sammaan Finserve and/or its group companies/affiliates.

We may share your personal data with Sammaan Finserve and/or its affiliates for providing details on latest offers from our other entities.

We respond to subpoenas, court orders, Government Authorities, law enforcement authorities for legal processes or to establish or exercise our legal rights or defend against legal claims where it becomes necessary to do so to protect the rights or property of Sammaan Finserve and/or its group companies/affiliates, etc.

We believe it is necessary to share data in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Sammaan Finserve terms of use, or as otherwise required by law.

We transfer data about you if Sammaan Finserve is acquired by or merged with another company. In this event, Sammaan Finserve will notify you before data about you is transferred and becomes subject to a different privacy policy.

Consent to International Transfer of Data
When you use or participate in any of our Services and/or provide us your details, your data may be transferred outside India for processing consistent with this Privacy Policy. Please note that the data protection laws of countries to which your data may be transferred will be at least same level as that of India.

In case your data is first processed in the European Union (EU), it may be transferred outside EU to share with Sammaan Finserve group companies, affiliates and/or trusted partners for processing consistent with this Privacy Policy. However, such transfers will be made only while appropriate protective measures exist to protect your transferred data (e.g. – contractual clauses with the respective entities with whom the data will be shared).

Third-Party Links and Content on Services
Our Services may link to third-party websites/applications and services that are outside our control. Further, Sammaan Finserve, its group companies, its affiliates, and their directors and employees accept no liability and will not be liable for any loss or damage arising directly or indirectly (including special, incidental or consequential, punitive, or exemplary loss, damage or expenses) from your use of any application or any site or inability to use by any party, howsoever arising, and including any loss, damage or expense arising from, but not limited to, any defect, error, omission, interruption, imperfection, fault, mistake or inaccuracy with any online application, its Contents (material, data, money market movements, news items, etc.) or associated services, or due to unavailability of any application or any part thereof or any Contents or associated services even if Sammaan Finserve are advised of the possibility of such damages, losses or expenses.

Minors
To use the Site/Application you agree that you must be the minimum age (described in this paragraph below) or older. The minimum age for these purposes shall be 16, however if local laws require that you must be older in order for Sammaan Finserve to lawfully provide the services in the Site/Application 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 Sammaan Finserve under the supervision of your parent, legal guardian or responsible adult.

Data Retention
Your personal data processed by Sammaan Finserve are kept in a form which permits your identification for no longer than is necessary for the purposes for which the personal data are processed in line with legal, regulatory, contractual or statutory obligations as applicable.

At the expiry of such periods, your personal data will be deleted or archived to comply with legal/contractual retention obligations or in accordance with applicable statutory limitation periods.

Control over Your Information
We also provide you with the ability to control your Personal Data in accordance with European Union’s General Data Protection Regulation, which includes the right to access, modify, erase, restrict, transmit, or object to certain uses of your data.

You have the ability to update your profile and related Personal Data at any time. Also, you may review, update, correct, delete or object your Personal Data collected through the website/applications or service by e-mailing us at privacy@sammaanfinserve.com

If you have privacy concerns regarding access to or the correction of your Personal Data, please contact us at the contact information mentioned within the section called “Data Privacy Issues and Whom to Contact” of this policy.

In your request, please make clear what Personal Data you would like to have changed, whether you would like to have your Personal Data that you have provided to us suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Data that you have provided to us.

While the majority of questions and issues related to access or requests can be handled quickly, complex requests may take more research and time. In such cases, issues will be addressed, or you will be contacted regarding the nature of the problem and appropriate next steps, within 30 days.

Security and Confidentiality
Sammaan Finserve makes sure at all times to implement reasonable security practices and procedures (such as managerial, operational, physical and technical) for the purpose of protection and safeguarding of your personal data as the same is of vital importance to Sammaan Finserve. At Sammaan Finserve, we are strongly committed to protecting the personal and financial data that you submit to us.

Sammaan Finserve shall ensure to safeguard the security and confidentiality of any data you share with us. Any of your personally identifiable data obtained by us shall not be used or shared other than for the purposes to which you consent. However, despite our utmost efforts to protect your Personal Data, Sammaan Finserve cannot warrant the security of any data you transmit to us through our online services/ applications. By accepting this Privacy Policy, you accept that such transmission of your Personal Data is done at your own risk.

Lastly, you are requested to help us protect your data privacy by maintaining the secrecy of the username and password you use for any of our Services.

Reasonable security practices and procedures
Sammaan Finserve is ISO 27001:2022 compliant. We seek to use reasonable organizational,technical and administrative measures to protect Data within our organization. However, if you have reason to believe that your interaction with us is no longer secure, please immediately notify us.

Social media
Sammaan Finserve operates channels, pages and accounts on some social media sites to inform, assist and engage with customers. Sammaan Finserve monitors and records comments and posts made on these channels about Sammaan Finserve in order to improve its products and services.

Please note that you must not communicate to Sammaan Finserve through such social media sites the following information:

• sensitive personal data including (i) special categories of personal data meaning any data 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.

Sammaan Finserve is not responsible for any information posted on those sites other than the information posted by its employees on its behalf. Sammaan Finserve is only responsible for its own use of the personal data received through such sites.

Consent
Consent is often referred to as an individual’s choice to “opt-in” to or “opt-out” of the use of their Personal Data and is usually obtained by a “check box” or signature confirming the individual understands and agrees to the processing of their Personal Data. At times, express written consent from you may be required based on the data processing activity. Whenever required, we take consent from you prior to: collecting, using, or processing your Personal Data, including sensitive personal data, in certain ways or sharing the your Personal Data with any third party (sensitive personal data is data revealing an your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning sex life or sexual orientation);transferring your Personal Data outside of your country of residence; using or placing web cookies on your computer or other electronic devices.

Should You Want To Opt Out
If we possess your contact information, we may want to keep you posted about our products, services and events, through email. Should you prefer not to keep up to date with Sammaan Finserve news and latest information on services and receive such marketing materials, please send an email to unsubscribe@sammaancapital.com

1.1.1 Data Principal Rights

a. Sammaan Finserve is responsible for ensuring that the rights of data principals are protected through adequate mechanisms like web forms, email ID, etc. which facilitate and address requests within the period specified by applicable laws. The following are some of the data principal rights enshrined in the law, for which Sammaan Finserve is required to provide a mechanism:

• Right to access personal data: Data principals have the right to request a summary of their personal data processed by Sammaan Finserve, a copy of their personal data, along with the identities of all Sammaan Finserve stakeholders and any third-party vendors or partners their personal data has been shared with, to the extent permitted by law.

• Right to correction and erasure: Data principals have the right to request correction of errors or updates to their personal data, and have the right to request erasure of personal data in possession of Sammaan Finserve, if not required by Sammaan Finserve.

• Right of grievance redressal: Data principals have the right to readily available means of grievance redressal provided by Sammaan Finserve with regard to its obligations in relation to personal data of the data principal. Sammaan Finserve is required to address these grievances in a timely manner as prescribed from the date of receipt.

• Right to nominate: Data principals also have the right to nominate an individual who can exercise their rights in case of death or incapacity of the data principal, in accordance with the Digital Personal Data Protection Act, 2023 and any rules made thereunder."

b. Data Principals can request the exercise of any of their data principal rights by submitting their request through [enter details] or by contacting the Data Protection Officer (DPO) at:

i. Email: privacy@sammaancapital.com
Phone: 01246681519
Mail address: Sammaan Finserve Limited,
2nd Floor, Plot No-3, Block-A, Pocket-2,Sector-17, Dwarka Residential Scheme, Dwarka, New Delhi - 110075,

However, such withholding of data or withdrawal of consent may result in us not being able to provide services and facilities and we reserve its right to take appropriate action with respect to any obligations or in relation to any contract under which such Personal Data was sought.

We will update your preferences as soon as reasonably practical. However, do note, if you opt out of our emailing list, as described here, we may not be able to remove your Personal Data from all databases of Sammaan Finserve or other 3rd parties. For that, you would need to raise a request to erase your data as mentioned in the above section (control over your data).

Disclaimer
Sammaan Finserve shall not be liable for any loss or damage sustained by reason of disclosure (inadvertent or otherwise) of any data concerning the user's account and / or data 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 data so disclosed and used whether or not in pursuance of a legal process or otherwise. Sammaan Finserve does not store any Credit Debit card details. Any other personal and sensitive Personal Data shared by you which is not asked by Sammaan Finserve during registration, either mandatorily or optionally; accounts to wilful and intentional furnishing; and Sammaan Finserve will not be liable for breach of such data.

No contractual obligation
Please note that this Privacy Policy does not create any contractual or other legal rights in or on behalf of any party, nor is it intended to do so.

Intellectual Property Rights
Please note that Sammaan Finserve retains all rights (including copyrights, trademarks, patents as well as any other intellectual property right) in relation to all information provided on or via this web site/applications (including all texts, graphics and logos).

Changes to this Privacy Policy
Sammaan Finserve reserves the right to change or update this Privacy Policy or any other of our policies/practices at any time without giving any prior notification; hence, you are requested to review the Privacy Policy periodically, to make sure that you are aware of any such changes. This Privacy Policy shall apply uniformly to Sammaan Finserve website and Sammaan Finserve applications or any other media used by Sammaan Finserve for its Services. Any changes or updates will be effective immediately upon posting the same on our web site at www.sammaanfinserve.com.

1.1.2 Grievance Redressal
If you have any questions, comments or concerns about this Privacy Policy or about how we handle your Personal Data, please get in touch with us at privacy@sammaancapital.com

Sammaan Finserve reserves the right to modify or review the provisions in this Policy without prior notice and the revised Policy will be in effect from the day of uploading. Therefore, Users are requested to periodically visit the mobiles app/Site and review the Policy