PRIVACY POLICY

BillMart FinTech Private Limited, a company incorporated in India, together with its affiliates ("BillMart", "Company", "we", "us" or "our"), is committed to protecting the privacy and personal information of persons who interact with us, including our customers, business partners and other users ("User", "You" or "Your").

This Privacy Policy explains how BillMart collects, uses, processes, stores and shares information provided by or collected from Users while using our websites, web applications, mobile applications and other digital platforms, including www.billmart.com (collectively, the "Platform").

This Privacy Policy has been framed in accordance with applicable laws and regulations relating to privacy and protection of personal data in India, including the Information Technology Act, 2000 and other applicable data protection laws, as amended from time to time.

Additional notices, consent screens or disclosures may be provided on the Platform in relation to specific services or processing activities.

Please read this Privacy Policy carefully and make sure that you fully understand and agree to it.

By accessing or using the Platform and providing Your information, You acknowledge the collection, use and processing of Your information in accordance with this Privacy Policy and applicable law.

For the purposes of this Privacy Policy, "User Information" means information relating to an identified or identifiable User which is provided by You or collected by us in connection with Your use of the Platform.

For purposes of describing how information is handled on the Platform, User Information may include

  • Information provided by or on behalf of a User in connection with the services ("Personal Information"),
  • information collected through use of the Platform ("Application User Data"), and
  • information relating to visitors or prospective customers or partners who interact with BillMart websites, content, emails or communications ("Website Data").

Where consent is the appropriate or required legal basis for processing, BillMart will process User Information on the basis of the consent provided by the relevant individual, including through applicable consent notices, terms, product journeys or other lawful mechanisms. A User providing information on behalf of another individual is responsible for ensuring that it has the authority and, where required, the informed consent necessary to provide such information to the Platform.

For the purposes of this Privacy Policy:

  • "Data Fiduciary" / "Data Controller" means the person or entity that determines the purpose and means of processing User Information, to the extent applicable under relevant law and
  • "Data Processor" / "Service Provider" means the person or entity that processes User Information on behalf of a Data Fiduciary / Data Controller, to the extent applicable under relevant law.

The respective role of BillMart, a User, lending partner, regulated entity or third-party service provider may therefore vary depending upon the particular processing activity and applicable legal requirements.

1. INFORMATION COLLECTED AND PURPOSE OF PROCESSING

User Information collected which we analyze, process, and manage are a part of the service provided by the Platform. This data is proprietary to the User and includes (a) registration details, (b) financial information, (c) KYC details, (d) either or combination of the aforesaid or information through independent / third party agencies/entities requisite for the offering of services (e) all other data as may be required from time to time in order for smooth offering of services through the Platform.

You understand that the User Information qualifies as 'sensitive personal data' under the Indian IT Act, and consents sharing of the same with the Platform. If You reside or are using the Platform in a territory governed by privacy laws under which "consent" is the only or most appropriate legal basis for the processing of personal data as described herein, Your acceptance of our Terms and Conditions and this Privacy Policy will be deemed as Your consent to the processing of Your personal data for all purpose detailed in this Privacy Policy.

BillMart will collect and process User Information only where reasonably necessary for the applicable product, service or program, for the purposes specified below or otherwise communicated to You through an applicable notice or consent mechanism, and subject to applicable legal and regulatory requirements.

User Information Purpose of Collection and Use
Name Identification, onboarding, KYC and communication
Mobile Number Authentication, communication and servicing
Email Address Communication, documentation and servicing
Date of Birth Identity verification, eligibility and compliance
Gender Identification and compliance
Residential / Correspondence Address KYC, verification and communication
Photograph / Selfie, where required Identity verification and fraud prevention
PAN KYC, verification, assessment and compliance
Aadhaar-related information, where permitted under applicable law KYC and identity verification
Other KYC / Identity Documents, where applicable Identification, verification and compliance
Employment / Occupation / Professional Information Verification, eligibility and assessment
Employer / Organisation Information associated with You Verification and administration of applicable programs
Salary / Income Information, where applicable Eligibility, assessment and repayment-capacity evaluation
Bank Account Information Verification, disbursement, repayment and servicing
Bank Statements / Financial Information, where required Financial assessment and eligibility
Credit Bureau / Credit Information, where applicable Credit assessment, eligibility and compliance
User Information of an individual associated with or acting for a business or organisation, including an authorised representative, director, partner, proprietor, owner, beneficial owner or authorised signatory Identification, verification, authorisation, onboarding and compliance
IP Address / Device Identifier or similar technical information, where capable of identifying an individual Security, authentication and fraud prevention

Where a business, enterprise, proprietorship, partnership, company or other organisation participates in business financing or any other program through the Platform, BillMart may collect User Information relating to the natural person acting for, representing or associated with such organisation.

Such individual may include an authorised representative, director, partner, proprietor, owner, beneficial owner, authorised signatory or other individual whose identification or verification is reasonably necessary for onboarding, authorisation, KYC / KYB, regulatory compliance or administration of the relevant program.

Where consent is required under applicable law, BillMart will obtain appropriate consent before collecting, processing or sharing the relevant User Information. User Information will be processed only for the purposes disclosed to You, purposes reasonably connected with the applicable product or service, or as otherwise permitted under applicable law.

Where You provide User Information relating to another individual, including while acting on behalf of a business or organisation, You are responsible for ensuring that You are authorised to provide such User Information and that any required consent or other lawful basis has been obtained.

BillMart does not sell User Information.

2. HOW WE COLLECT USER INFORMATION

Depending upon the applicable product or service, User Information may be collected:

  • Directly from You during registration, onboarding, application or use of the Platform
  • Through forms, documents and information submitted by You
  • From Your employer or organisation where the relevant product or program is facilitated through such employer or organisation
  • From the business or organisation that You represent, where applicable
  • From the applicable Lending Partner / Regulated Entity
  • From authorised KYC and identity-verification service providers
  • From authorised bank-account verification service providers
  • From Credit Information Companies / credit bureaus, where permitted and authorised
  • From government, regulatory or other authorised sources where permitted under applicable law
  • From authorised technology or service providers and
  • Through Your use and interaction with the Platform

Where User Information is provided by another person, employer, organisation or authorised source, BillMart will process such User Information in accordance with applicable legal, regulatory and contractual requirements.

3. LENDING PARTNER / REGULATED ENTITY

BillMart acts as a technology platform / Lending Service Provider ("LSP") and does not itself sanction or disburse loans.

For the purpose of processing, sanctioning, disbursing and/or servicing a loan application, BillMart may share relevant User Information with the Lending Partner, including KYC, identification, employment, salary, financial, bank account, credit and loan-related information and, where applicable, User Information relating to an individual acting for or associated with a business, subject to applicable law and consent requirements.

Lending Partner is responsible for the assessment, sanction and disbursement of loans in accordance with its applicable policies and regulatory requirements.

For loan products currently facilitated through the BillMart, the Lending Partner is:

FYNX Capital Limited
(formerly known as Rajath Finance Limited)

Reserve Bank of India registered Non-Banking Financial Company ("NBFC")
RBI Certificate of Registration No.: B-13.02490

Office No 1001, 10th floor, K. P Aurum Building, Marol Maroshi Road, Andheri (E) Mumbai - 400059, Maharashtra, India
https://fynxcapital.com/contact

Users should review the applicable Key Fact Statement, loan terms and Loan Agreement before accepting any loan product.

4. HOW WE SHARE YOUR INFORMATION

BillMart takes reasonable measures to ensure that access to User Information is restricted to persons and organisations having a legitimate requirement to access such information.

We may share User Information with the following parties:

4.1 Lending Partner / Regulated Entity

User Information may be shared with the applicable Lending Partner / Regulated Entity, as identified in Section 3 above, where necessary for evaluating, processing, sanctioning, disbursing, servicing or recovering a loan or financing facility.

4.2 Service Providers

We may engage authorised third-party service providers for services including:

  • KYC and identity verification
  • Bank account verification
  • Credit bureau and credit information services
  • Eligibility and credit assessment
  • Reconciliation and settlement
  • Repayment tracking
  • Data hosting and infrastructure
  • Security and fraud prevention
  • Communication services
  • Analytics
  • Customer support
  • Payment and transaction-related services and
  • Legal, financial and compliance services

Such information will be shared only to the extent reasonably necessary for the applicable service and subject to relevant contractual and legal requirements.

Depending upon the nature of their services, such third-party service providers may act as Data Processors / Service Providers processing information on behalf of BillMart or another applicable Data Controller / Data Fiduciary.

4.3 Affiliates

We may share User Information with our subsidiaries or affiliates where reasonably necessary for providing services or for purposes described in this Privacy Policy.

4.4 Government and Regulatory Authorities

We may disclose User Information agencies, regulatory authorities, courts, tribunals or law-enforcement authorities where required under applicable law or lawful directions, for regulatory reporting or compliance, or where reasonably necessary to investigate or prevent fraud, unlawful activity or misuse of the Platform, or to protect the security, legal rights and legitimate interests of BillMart, its Users or the Platform.

4.5 Business Transfers

In case of any merger, acquisition, restructuring, transfer of business or similar corporate transaction involving BillMart, User Information may be transferred as part of such transaction in accordance with applicable law.

5. THIRD-PARTY WEBSITES AND SERVICES

The Platform may contain links to third-party websites or may integrate with third-party services.

Information provided directly by You to such third-party services will be governed by their respective terms and privacy policies.

BillMart encourages Users to review the privacy policies of third parties before providing any information to them.

6. DATA RETENTION

We retain User Information only for as long as reasonably necessary:

  • To provide services through the Platform
  • To maintain our contractual relationship with You
  • To service existing transactions, loans or financing facilities
  • To comply with legal, regulatory, accounting and record-keeping requirements
  • To resolve disputes and
  • To protect our legal rights

Where information is no longer required, it may be securely deleted, anonymised or otherwise processed in accordance with applicable law and our data retention policies.

Where BillMart processes User Information in connection with digital lending, such information will be stored and retained in accordance with applicable RBI requirements and the arrangements with the relevant Regulated Entity.

For questions relating to retention of Your information, You may contact us at care@billmart.com

7. DATA LOCATION

BillMart and its authorised service providers may store and process User Information in India or in such locations as may be permitted under applicable law.

BillMart and its authorised service providers are required to maintain appropriate safeguards for protecting User Information in accordance with applicable legal and contractual requirements.

8. COOKIES AND SIMILAR TECHNOLOGIES

Our website and Platform may use cookies and similar technologies to:

  • Maintain User sessions
  • Remember preferences
  • Facilitate log-in
  • Understand Platform usage
  • Improve performance
  • Conduct analytics and
  • Improve User experience

Cookies may be session-based or may remain on Your device for a specified period.

You may control cookies through Your browser settings, although disabling certain cookies may affect some Platform functionality.

9. YOUR PRIVACY RIGHTS AND CHOICES

Subject to applicable law, You may have the following rights in relation to Your User information:

9.1 Right to Access

You may request information regarding personal information held by us about You.

9.2 Right to Correction or Update

You may request correction or updating of inaccurate or incomplete information.

For assistance, You may contact care@billmart.com

9.3 Right to Withdraw Consent

Where processing is based on Your consent, You may withdraw Your consent in accordance with applicable law.

Withdrawal of consent will not affect processing already undertaken lawfully before such withdrawal.

Where certain information is necessary for providing a service, withdrawal of consent may result in BillMart being unable to continue providing such service.

9.4 Right to Erasure

You may request deletion of Your User Information, subject to legal, regulatory, contractual and record-retention obligations applicable to BillMart or the relevant lending partner.

9.5 Right to Restrict or Object to Processing

Where applicable under law, You may request restriction of processing or raise concerns regarding the manner in which Your user information is being processed.

9.6 Marketing Communications

You may opt out of promotional communications from BillMart.

However, You may continue to receive transactional, regulatory, account-related or service-related communications where necessary.

9.7 Exercise of Rights

To exercise any applicable privacy rights, please contact:

Email: care@billmart.com

We may verify Your identity before processing a request in order to protect Your information and account.

Where User Information is processed by BillMart solely on behalf of another Data Controller / Data Fiduciary, certain requests relating to such information may need to be addressed to or coordinated with the relevant Data Controller / Data Fiduciary, as applicable.

10. DATA SECURITY

BillMart maintains reasonable technical, organisational and physical security safeguards designed to protect User Information against unauthorised access, disclosure, alteration, misuse, loss or destruction.

We also require authorised third-party service providers handling user information to maintain appropriate security measures.

While BillMart takes reasonable steps to protect Your information, no electronic storage, transmission or information system can be guaranteed to be completely secure.

11. ACCOUNT DELETION

You may request deletion of Your BillMart account through the functionality available on the Platform or by sending an email from Your registered email address to care@billmart.com

An account may not be deleted where:

  • There are active or outstanding transactions
  • A loan or financial obligation remains active
  • Information is required to be retained under applicable law
  • There is an ongoing legal, regulatory or statutory requirement or
  • Retention is necessary for fraud prevention, dispute resolution or compliance purposes

Subject to applicable legal, regulatory, contractual and record-retention requirements, personal information that is no longer required may be deleted or de-identified within a reasonable period, not exceeding 90 days in accordance with BillMart’s applicable retention and deletion processes

Deletion of Your BillMart account does not necessarily require deletion of information independently maintained by a lender, regulated entity or other third party where such entity is legally required or entitled to retain such information.

Once Your account is deleted, You may not be able to retrieve or access the account or associated information.

12. CHILDREN'S PRIVACY

The Platform and loan-related services are intended for persons who are legally eligible to enter into the applicable transactions and are not intended for use by minors for obtaining credit facilities.

We do not knowingly offer loan products to persons who are not legally eligible to enter into the relevant loan transaction.

13. UPDATES TO THIS PRIVACY POLICY

BillMart may update this Privacy Policy from time to time to reflect changes in:

  • Applicable laws or regulatory requirements
  • Our products and services
  • Our data processing practices or
  • Our business operations.

The updated Privacy Policy will be published on the Platform together with the revised "Last Updated" date.

Where required under applicable law, we may provide additional notice regarding material changes.

14. DATA PROTECTION & GRIEVANCE REDRESSAL

The Company has appointed a Data Protection Officer ("DPO"), for monitoring and advising on the Company's ongoing privacy compliance and serving as a point of contact on privacy matters for data subjects and supervisory authorities.

If You have any comments or questions regarding our Privacy Policy, if You have any concerns regarding your Privacy, or if You wish to make a complaint about how Your User Information is being processed by the Company, You can contact our DPO at compliance@billmart.com

For any other complaints or grievances may be submitted to: Grievance Redressal Email: care@billmart.com

Users may submit complaints, queries or requests to the DPO / Grievance Officer at the email address mentioned above. The DPO / Grievance Officer will acknowledge and address such complaint, query or request within the timelines prescribed under applicable law.

We will endeavour to address privacy-related requests or grievances in accordance with applicable law.

15. CONTACT US

For general queries or support relating to BillMart or the Platform, please contact:

BillMart FinTech Private Limited
Email: care@billmart.com

For queries specifically relating to the Lending Partner, Users may also refer to the lender information, grievance redressal details and contact information provided in the applicable loan documentation, Key Fact Statement or on Lending Partner official channels.

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