Privacy Policy

1. WHAT/WHO IS INNOTECH CREDITSEA AND HOW DOES INNOTECH CREDITSEA'S PRIVACY POLICY WORK?
1. Innotech Creditsea Platforms Private Limited (“we”, “our”, “us”, “creditsea”) (CIN: U62099CT2024PTC016603), is a company incorporated under the Companies Act, 2013, having its registered office at SO-11, 3rd Floor, Magneto, The Mall, Telibandha, Raipur, Chhattisgarh, India - 492001. Creditsea operates primarily in the financial products and services sector, utilizing technology platforms such as Websites, Apps, and Platforms (defined below), along with providing data processing services to customers and businesses. We collaborate with various Partner Lenders registered with the Reserve Bank of India (“RBI”) to deliver financial products and services
2. The purpose of this privacy policy ( Creditsea Privacy Policy”) is to inform you about how Creditsea collects, stores, uses, discloses, transfers, and processes your Personal Information, including Sensitive Personal Information (defined below). This occurs when: (a) you use our Websites, software applications, mobile applications, or our partners’ platforms (“Platforms”), or (b) you access products or services directly through our Websites, Apps, or Platforms. This policy also outlines the measures we take to safeguard your Personal Information. The term Websites encompasses all pages, sub-domains, or associated content within each Website.
3. By accessing the Websites, Apps, Platforms, and/or using products or services provided by Creditsea, either directly or indirectly, you acknowledge that you have read, understood, and agreed to be bound by this Creditsea Privacy Policy.
4. While accessing the Websites, Apps, Platforms, and/or using our products or services now or in the future, you may need to give specific and prior consent for us to collect, use, store, disclose, or process your Personal Information, including Sensitive Personal Information.
5. You also acknowledge and agree that any consent you previously provided on our Websites, Apps, Platforms, or during use of our services applies to your Personal Information and Sensitive Personal Information submitted to us, directly or indirectly, in the past.
6. We strongly recommend that you revisit this page periodically to review the latest version of this Creditsea Privacy Policy, as it may be updated by us from time to time.
2. WHAT IS PERSONAL INFORMATION AND WHAT TYPES OF PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?
1. “Personal information” refers to any data that pertains to an individual and can directly or indirectly identify that person, either on its own or in conjunction with other information we have or may have access to.
2. “Sensitive Personal Information” includes any personal details relating to financial data such as bank accounts, financial history, credit history, credit or debit card details, passwords, biometric data, sexual orientation, physical, physiological, and mental health conditions, as well as medical records and history. Information that is freely available or accessible in the public domain is not considered Sensitive Personal Information.
3. Depending on your role (e.g., merchant, customer, borrower, consumer, supplier, or business partner) and how you engage with us (e.g., through Websites, Platforms, Apps, telephone, IVR, API, email, online, or offline), we may collect, use, receive, store, analyze, combine, transfer, or otherwise process various categories of your Personal Information, including Sensitive Personal Information.
4. Below is a breakdown of the categories of Personal Information and Sensitive Personal Information that we may collect about you:
1. Identity and Account Login Information: Includes full name(s), title, age, user ID, gender, and date of birth.
2. Contact Information: Personal details such as bank account numbers, e-NACH, NEFT, IMPS, and UPI ID details, credit or debit card information (including card number, type, expiry date, and cardholder name), financial history, credit history, salary, and income details.
3. Identification Information: KYC documents, proofs of identity and address, photograph, PAN (Permanent Account Number), GST Number, etc.
4. Payment Information (Transactional Information): Details like payment gateway ID, issuing bank name, merchant details, product or service identifiers, payment mode, transaction date, currency, amount, transaction status, and additional information provided directly or indirectly by you, banks, merchants, service providers, or business partners.
5. Usage and Technical Information: IP addresses, device/browser type, versions/configurations, operating systems, device brand/model, time zone settings, geo-location data, content accessed, unique identifiers associated with your device(s), pages visited on Websites, Apps, or Platforms, visit times/dates, and navigation paths.
6. Credit and Lending Information: Credit-related details, income information (e.g., employment contract, salary details, employer name, income tax returns, bank statements, income statements, balance sheets, cash flow statements), credit scores or reliability scores provided by financial institutions, credit information companies, account aggregators, or similar third parties as permitted by applicable Indian laws, including our partners, service providers, and group entities.
7. Marketing and Communications Information: Customer service communications, behavioral data (e.g., cookie-based data), details about promotions, surveys, promotional campaigns, and records of your subscription preferences or withdrawals from receiving marketing materials.
8. Device/Phone Data: SMS data, camera usage, microphone usage, location data, media/files, or other device facilities (including mobile phones) used for onboarding/KYC purposes related to loan or credit applications, with necessary permissions obtained.
9. CreditSea accesses SMS logs on the customer's mobile device, specifically targeting non-personal messages sent by 6-digit alphanumeric senders. These messages are scanned solely to identify financial transactions across various bank accounts the customer may own. The purpose is to analyze cash flow trends, transaction descriptions, and amounts to assess income and expenditure patterns. This information enables us to evaluate credit risk and generate suitable credit analyses or loan offers. Please note, we do not read or collect any personal SMS messages.
5. We may also enable Partner Lenders to access Phone Data from your mobile device for the purposes of onboarding, credit risk assessments, and related activities in connection with your loan or credit facility application. Creditsea collects such Phone Data as a one-time activity, limiting the collection to the duration necessary to complete your loan application on our Websites, Apps, and Platform. While we facilitate the collection of Phone Data from you, Creditsea does not have access to or store this data for any purposes; any storage will be managed by the Partner Lenders alone
6. Creditsea collects such Phone Data as a one-time activity, limiting the collection to the duration necessary to complete your loan application on our Websites, Apps, and Platform. While we facilitate the collection of Phone Data from you, Creditsea does not have access to or store this data for any purposes; any storage will be managed by the Partner Lenders alone
7. As a matter of principle, we do not collect certain special categories of Personal Information, such as details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, health information, or any genetic and biometric data. However, we may collect certain Sensitive Personal Information necessary to provide our services or products to you, such as financial information including bank account numbers, credit or debit card details, and your Credit and Lending Information. In such instances, we ensure that this Sensitive Personal Information is used, processed, stored, and/or disclosed in accordance with the Creditsea Privacy Statement and in compliance with applicable laws of India.
8. If the Websites, Apps, or Platforms include links to third-party websites, plug-ins, and applications (including cookies, tracking technologies, and widgets by third-party advertisers), you should understand that by clicking on those links or enabling those connections, you may allow third parties to collect or share data about you. Creditsea does not oversee these third-party websites, plug-ins, and applications and is not responsible for their processing or use of your Personal Information or Sensitive Personal Information. Any information collected by a third party in this manner is subject to that third party’s own data collection, use, and disclosure policies, and you should familiarize yourself with those policies.
3. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
1. The methods by which we collect your Personal Information (including Sensitive Personal Information) vary based on different scenarios:
1. Direct Collection from You: We gather Personal Information directly from you through various interactions on our Websites, Apps, Platforms, or during any product or service offerings. Examples include:
1. Providing your Contact Information for communication about our services and products.
2. Entering into a contract or verifying your identity through email, phone, or electronic means.
3. Submitting your Personal Information on our Apps, Websites, Platforms, or checkout pages to register for our services, take out a credit facility, or complete a transaction
4. Applying for our products or services, either directly or through our business partners such as third-party websites, merchants, resellers, or other credit providers.
5. Registering with us directly to avail of any products or services, including initiating an account-based relationship.
6. Providing Identity and Account Log-In Information, Contact Information, Financial Information, Identification Information, and/or Payment Information on our App, Website, or payment pages to register for or complete a transaction.
7. Participating in a competition, promotion, or survey, or consenting to receive marketing materials
8. Sending support requests for our products or services through one or more of our support desks.
9. Accessing, using, and/or browsing our Websites, Apps, or Platforms.
10. Granting one-time access to Phone Data and other sources via cookies or other means
2. Collection from Third Parties or Publicly Available Sources:
1. We also collect Personal Information through third parties, business partners, independent service providers, group entities, or from publicly available sources as permitted by applicable Indian laws. Examples include:
1. Receiving information from merchants, marketplaces, resellers, banks, payment partners, payment aggregators, payment systems, payment service providers, credit information companies, and financial institutions. For example, a financial institution might share your information to check eligibility for our services.
2. Obtaining information from group entities or independent third parties for activities such as internal analysis or credit checks, and from Partner Lenders or other third parties during service provision.
3. Gathering Phone Data for operational reasons, such as referrals.
2. Collecting data from social platforms and networks when you grant permission, either directly or through cookies. For example, based on your social media settings, if you connect your social media account to an Creditsea product or do not disable cookies, certain information from your social media account may be shared with us.
3. Acquiring information from financial institutions and fraud prevention agencies for fraud and risk assessments. Before providing services, goods, or finances, we may conduct checks to prevent fraud and money laundering and verify your identity, requiring us to collect information from our business partners and independent service providers, including technology providers under contract
4. Receiving credit information from companies like TransUnion, CIBIL Limited to share with Partner Lenders and their service providers.
5. Engaging third-party service providers or technology providers who assist with our business operations by collecting data from publicly available sources under contract.
6. Obtaining information from third parties such as merchants or e-commerce platforms that have a contract with you or have obtained your consent or other legal means under applicable Indian laws to share your information.
7. Collecting data from publicly available sources in compliance with applicable Indian laws.
4. WHAT ARE THE LAWFUL GROUNDS THAT WE RELY ON TO PROCESS YOUR SENSITIVE PERSONAL INFORMATION?
1. We process Sensitive Personal Information only with your explicit consent, as outlined below. By this Creditsea Privacy Statement, we seek your consent and provide notice regarding the collection, processing (including use and storage), disclosure, or sharing of your Sensitive Personal Information for one or more purposes detailed herein. When specific consent is required by applicable Indian laws, we will obtain such consent from you as necessary.
2. For information obtained from third parties or group entities, we rely on the consent these parties have obtained on their respective platforms on our behalf.
3. You may choose not to share certain information with us; however, this may limit our ability to provide some or all features and functionalities of our Websites, Apps, and Platforms. Consequently, this may affect our ability to process your Personal Information (including Sensitive Personal Information) and could result in the unavailability or discontinuation of services that require such information, at our discretion.
5. PURPOSES FOR PROCESSING YOUR PERSONAL INFORMATION
1. We process your Personal Information, including Sensitive Personal Information, for the following purposes:
1. Verification and Authentication: We use your Personal Information to verify, authenticate, and authorize your use of our products or services. This includes creating login credentials, establishing account-based relationships, conducting KYC evaluations, and performing risk assessments. Depending on your role (merchant, consumer, borrower, service provider, or business partner) and your chosen services or products, we may require Identification Information, Identity and Account Log-In Information, Contact Information, and Financial Information. This is necessary for both Creditsea and our Partner Lenders to assess your application and fulfill legal obligations under Indian laws.
2. Transaction Processing: To provide products or services, we may need to collect specific Personal Information, which varies based on the product offered by Creditsea or our Partner Lender. Credit and repayment transactions may require you to provide Personal Information directly through our Websites, Apps, or Platforms, especially when using a credit facility for purchases or payments.
3. Service Provision: We process your Personal Information to deliver the products or services offered by us, our group companies, or business partners. This includes improving your experience on our Platforms, Websites, Apps, and merchant platforms. If other entities offer products or services on these platforms, we also process your Personal Information accordingly.
4. Internal Risk Assessments and Analysis: We may process your Personal Information for risk assessments, KYC checks, service improvements, fraud reduction, and risk model development.
5. Business Protection and Legal Compliance: We process your Personal Information to comply with applicable laws, regulations, standards, and codes. This includes authenticating your account access, protecting against identity theft and fraud, and fulfilling reporting obligations. We may collect and use information for anti-fraud systems and retain it for future reference. Additionally, we consult and report your information to financial or risk assessment centers as required by law or contracts, and verify your identity to ensure compliance with payment scheme rules and KYC norms.
6. Relationship Management: If you contact us or provide your Contact Information, we process your Personal Information to inform you about our products or services, notify you of service interruptions, request feedback for improvement, and communicate effectively with you. We also provide service assistance, problem solutions, and notifications related to the services or products you use.
7. Marketing: We use your Personal Information to market our products and services, including those of our business partners, independent service providers, and group entities. This includes informing you about events, offers, sponsorships, marketing programs, and campaigns. We also analyze your usage trends and preferences to develop and market new products, services, features, and functions based on this analysis.
8. Research and Development: We use your Personal Information for research to gain market insights and develop technologies, products, and services. This may involve machine learning and artificial intelligence techniques. We analyze visitor usage of our Websites, Apps, Platform, products, or services to improve and personalize our merchant and customer relationships. We also provide statistical insights and reports to our business partners or third parties based on the information we receive.
6. WHEN AND TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?
1. We may share your Personal Information, including Sensitive Personal Information, in the following scenarios:
1. Support and Technical Services: We share information with business partners, third parties, and service providers to receive and provide support and technical services.
2. Research and Analytics: We disclose information to contribute to research, data analytics, and studies aimed at improving our products and services
3. Product and Service Offerings: We share your information to offer you products and services, including combined offerings from our partners.
4. Phone Data Sharing with Partner Lenders: We share Phone Data with Partner Lenders to assess your eligibility for loans or credit facilities. Partner Lenders use this data for credit risk assessments and related activities connected to your application. We advise you to review the privacy policies of Partner Lenders to understand their data processing practices.
5. Credit Information Sharing: Partner Lenders may share your credit information, documents from credit information companies, and KYC details with their affiliates, group companies, Creditsea, and its agents or service providers. This is done for evaluating applications, conducting credit assessments, onboarding, due diligence, and monitoring creditworthiness. Again, reviewing Partner Lenders’ privacy policies is encouraged.
2. External Third Parties, We may share your information with:
1. Other Third Parties and Financial Institutions: To enable these entities to market and offer their products and services to you, and to understand your interests, habits, and usage patterns for certain programs, services, advertisements, and promotions.
2. Merchants: According to our service agreements, either directly or through third parties like payment aggregators or referral partners.
3. CKYC (Central KYC Registry): As required by Indian law.
4. Authorized Financial Institutions and Banking Partners: With whom we collaborate to create and offer products and services.
5. Third-Party Service Providers or Vendors: Who assist us with business operations, including KYC processes, eligibility checks, and data storage as required by Partner Lenders.
6. Mergers and Acquisitions: Companies we plan to merge with or entities that we may acquire or be acquired by, ensuring they adhere to this Privacy Statement.
7. Legal and Regulatory Requirements: When required by law enforcement, government officials, fraud detection agencies, financial institutions, or other third parties, under applicable laws such as subpoenas, court orders, or regulatory queries.
8. International Entities: With whom we partner for the development or offering of products and services, subject to the requirements of this Privacy Statement and applicable laws.
9. For further details about service providers or third parties with whom your data will be shared, please contact us at: 8827973499.
7. MARKETING
1. Regarding the products and services we offer or those provided by third parties with whom we share your Personal Information and Sensitive Personal Information according to this Creditsea Privacy Statement, you may receive marketing communications from Creditsea or other business partners or third parties. These communications may come via messages, email, or other digital modes on Platforms, Websites, Apps, or social media platforms if you have shared your Personal Information or Sensitive Personal Information with us. We may use these communications to market our products and services, as well as those offered by third parties.
2. These marketing activities will comply with applicable laws. We have contracts with our merchants, service providers, banks, and other third parties for these marketing activities. You have the right to opt-out of receiving such marketing communications by clicking the opt-out link (if available), unsubscribing through the provided link, or writing to us at help@creditsea.com.
3. Creditsea may also use Marketing and Communications Information to enhance and tailor the content of our ads, promotions, and advertising to better suit your interests.
8. INTERNATIONAL DATA TRANSFERS
1. Your Personal Information and Sensitive Personal Information may be processed either locally in India or in other countries where our approved third-party service providers operate, as allowed by applicable laws. Transaction-related data, i.e., data concerning the products and services provided to you, will be stored in India. This Creditsea Privacy Statement seeks your consent to transfer your Personal Information (including Sensitive Personal Information) to our approved business partners and third-party service providers under designated contracts for the purposes defined here or as communicated to you from time to time.
9. DATA RETENTION
1. Creditsea will retain minimal Personal Information and Sensitive Personal Information necessary for our operational purposes. However, Partner Lenders will store Personal Information and Sensitive Personal Information for the duration required to fulfill the purposes for which the information was collected, including until you no longer have a loan or credit facility. The retention of Personal Information and Sensitive Personal Information by Creditsea and Partner Lenders considers compliance with legal (contractual, statutory, or regulatory requirements), accounting, and compliance reporting requirements.
2. Subject to your rights, the storage and purpose limitation restrictions provided in this Privacy Statement, and applicable laws, Creditsea will retain your Personal Information and Sensitive Personal Information for a maximum period of 10 years.
10. YOUR INDIVIDUAL RIGHTS
1. We are committed to enabling you to exercise your privacy rights under applicable laws and our internal policies. Creditsea aims to provide reasonable assistance with requests related to the processing of your Personal Information, the amendment of your Personal Information, and the withdrawal of consent for processing your Sensitive Personal Information. In accordance with applicable laws and our policies, you can exercise the following rights:
1. Review, Correct, or Rectify: You can request that we review, correct, or change any inaccurate Personal Information (including Sensitive Personal Information) we process about you within the timeframe specified by applicable laws.
2. Right to Access: You may request a record of your Personal Information (including Sensitive Personal Information) that we are processing, upon verification of your identity.
2. To exercise any of the above rights, please submit a request at help@creditsea.comNote that these rights are limited in certain situations, such as when we are legally obligated to process or retain your Personal Information (including Sensitive Personal Information). This may also impact our ability to process your Personal Information, potentially leading to the discontinuation of services or products that require this information, at our sole discretion.
3. Please note that you do not have an unqualified right to delete your Personal Information (including Sensitive Personal Information) under applicable laws. If you wish to delete your Personal Information, you will need to cease using the loan or credit facility immediately and settle all outstanding dues related to the loan or credit facility provided by Creditsea or its Partner Lenders. In such cases, Creditsea and/or the Partner Lenders will no longer be able to continue providing the loan or credit facility to you.
4. If you wish to delete your Personal Information (including Sensitive Personal Information) stored by Creditsea and/or its Partner Lenders, you may be required to clear all outstanding dues related to the relevant products and services. You can request this through Creditsea and/or the Partner Lender by submitting a request at help@creditsea.com. Be aware that the right to request data deletion is limited in some cases. If Creditsea and/or its Partner Lenders are legally required to process or retain your Personal Information for a specific period, they may continue to retain and process the information. A data deletion request may impact Creditsea and/or its Partner Lenders' ability to process your Personal Information, potentially leading to the discontinuation of services or products that require this information.
5. If you wish to revoke or withdraw your consent to collect, store, use, process, or share any Personal Information (including Sensitive Personal Information), please inform Creditsea by writing to help@creditsea.comand immediately cease using the loan or credit facility. You must also settle all outstanding dues related to the loan or credit facility provided by Creditsea and/or its Partner Lenders. In such cases, Creditsea and/or its Partner Lenders will no longer be able to provide the loan or credit facility to you.
11. SECURITY: HOW WE PROTECT & STORE PERSONAL INFORMATION
1. We prioritize the security of your Personal Information and Sensitive Personal Information. To this end, we implement a range of physical, technical, managerial, and operational measures designed to protect the integrity and security of the information we collect and maintain, as required by applicable laws. All Personal Information and Sensitive Personal Information are stored on servers located in India.
2. Creditsea routinely reviews its policies on the collection, storage, and processing of your Personal Information (including Sensitive Personal Information). This includes implementing physical security measures to prevent unauthorized access, alteration, loss, or fraudulent activity. We have procedures in place to address any breaches of Personal Information and will notify you, along with any relevant regulators or authorities, if required by law.
12. MINORS
1. Creditsea does not intentionally collect, use, or disclose Personal Information of minors, according to the minimum age equivalent in the relevant jurisdiction, without prior consent from a parent or guardian. Our services are not designed to attract minors. If we discover that we have inadvertently collected Personal Information (including Sensitive Personal Information) from a minor without verifiable parental consent, we will take reasonable steps to delete that information in accordance with applicable Indian laws as soon as possible.
13. CHANGES TO THE CREDITSEA PRIVACY STATEMENT AND YOUR DUTY TO INFORM US OF CHANGES
1. The Creditsea Privacy Statement may be updated or amended over time. The most current version of this Privacy Policy will be published on our Website, App, or Platform, as applicable. We encourage you to periodically review this page to stay informed about any changes. Any significant updates will be communicated via our Website, App, or Platform. By continuing to use our services after any amendments, you accept the revised Privacy Statement. If you disagree with the terms of the updated Privacy Statement, you should stop using our services and notify us.
2. It is crucial that the Personal Information and Sensitive Personal Information we have about you is accurate and up to date. Please inform us of any changes to your Personal Information and/or Sensitive Personal Information.
14. CONSENT
1. By submitting your data to us or our agent, or by using the Website or App, you consent to our use of your data in the manner and for the purposes described in this Privacy Policy
15. HOW TO CONTACT US
1. The controller of this Website, App, and/or Platform (as applicable) is Creditsea Services India Private Limited, with its registered office at SO-11, 3rd Floor, Magneto, The Mall, Telibandha, Raipur, Chhattisgarh, India - 492001 . We welcome any queries, concerns, or questions regarding the processing (including storing and using) of your information, which you can raise by writing to us at help@creditsea.com.

Any complaints or discrepancies related to the processing of your Personal Information can also be addressed to this contact. (Grief Redressal Officer - Mr. Anant Prasad - 8827973499)