Samavesh Finance India Private Limited

App Privacy Policy

Samavesh Finance India Private Limited (hereinafter referred to as “Tala” or “our” or “we” or “us”) values and respects your right to privacy. This Privacy Policy (“Policy”) aims to set out the details of the nature of information we collect and how we use, share or otherwise process such information in relation to our services. This Policy complies with inter alia the provisions of Information Technology (Reasonable Security Practices & Procedures & Sensitive Personal Data or Information) Rules, 2011 under the Information Technology Act, 2000, the RBI Guidelines on Digital Lending, and other applicable laws that require publishing of privacy policies for collection, usage, storage, disclosure and transfer of information.

By clicking ”Accept” on the relevant Tala App screen, you expressly agree and provide explicit consent to be bound by the terms of this Policy. If you do not agree with the terms of this Policy, you must immediately discontinue the use of and cease to access this App and any other services provided by Tala (collectively, the “Services”). This Privacy Policy does not apply to your use of Tala’s website, tala.co.in (“Website”). Please click here for the privacy policy applicable to your use of the Website.

You must be 18 years of age or above to use our App and, or, the Services.

SCOPE OF POLICY

This Privacy Policy applies to the App, the Services and any other online or mobile application that refers to or links to this Policy. This Policy applies regardless of whether you have downloaded or accessed the App onto your mobile telephone, handheld device or any other computer resource (each referred to herein as a “Device”).

This Policy applies to all concerned Users (a “User” is any person who downloads and/or accesses the App on any Device) whose information is collected, possessed, stored, received or otherwise dealt with by us in the course of providing the Services.

INFORMATION WE COLLECT

We collect and process various types of information within the App and as part of offering our Services. The information that we collect or process may fall within the category of “Personal Information” as we define that term below. We limit the collection and processing of Personal Information only to what is necessary for achieving the purposes as identified in this Policy.

Personal Information means any information pertaining to an individual natural person which, either directly or indirectly, in combination with other information, is capable of identifying such an individual.

You provide us with information, including Personal Information, by accessing our App or otherwise using our Services, including by corresponding or otherwise communicating with us. You may also provide us with information indirectly via your social media accounts. Information we collect from you with your explicit consent, or from your device in connection with your usage of the App, includes:

• Identity details, including name, date of birth, and government identification information (such as Permanent Account N​umber and Aadhaar);
• Mobile number, email address, home address, and other contact details;
• Financial information, which may include account and transactional information and history, responses submitted within the App, proof of income, and credit and borrowing history;
• Photograph/image and personal appearance;
• SMS logs and contents;
• Location information;
• Technical information, including the Internet Protocol (“IP”) address, the type of Device you use, unique device identifiers (for example, your Device’s “IMEI” or serial number), information about the mobile network provider and SIM card used by the Device, mobile network information, your Device’s operating system, the type of browser you use, the mobile applications installed on your Device, your Device’s technical specifications and settings;
• Details of your use of the App, such as page interactions and navigation; and
• Communications with Tala or Tala’s service providers, including call recordings, inquiries, and service requests and tickets.

In accordance with the RBI Guidelines on Digital Lending, a one-time access may be taken for camera, location, or other facilities necessary for the purpose of onboarding and KYC requirements, with your explicit consent. If you do not wish to provide consent for the collection and processing of such data, click “Deny” on the relevant screen or window in the App.  

We may also collect information about you from a limited number of third parties that we may work with from time to time to provide the Services, including but not limited to:

• Credit information from credit reference agencies or the lender of record, among others, in our capacity as your authorized representative;
• Transaction information from money service businesses, mobile network providers, payment and delivery service providers, collection agencies and analytics partners, to ensure that we effectively meet our obligations to you.

Tala does not collect or store biometric information except as may be necessary for the conduct of a one-time customer identification process under applicable regulations (such as the use of facial recognition technology to facilitate electronic KYC).

WHY WE COLLECT INFORMATION

Tala collects information, including your Personal Information, in order to provide the Services as described below:

Personal Data Processed	Purposes for Data Processing
Identity details, including name, date of birth, and government identification information (such as Permanent Account N​umber and Aadhaar)	– Identity verification – Fraud and crime prevention – KYC and account monitoring obligations under anti-money laundering regulations – Credit scoring and development or improvement of decisioning models – Transaction and funds processing – Contract fulfillment and collections – Administration of the App or your account – Ensuring network and information security
Mobile number, email address, home address, and other contact details	– Identity verification – Fraud and crime prevention – KYC and account monitoring obligations under anti-money laundering regulations – Credit scoring and development or improvement of decisioning modelsTransaction processing – Contract fulfillment and collections – Service improvement, training, research, analysis, and troubleshooting – Administration of the App or your account – Ensuring network and information securityMarketing and promotional offers
Financial information, which may include account and transactional information and history, responses submitted within the App, proof of income, and credit and borrowing history	– Identity verification – Fraud and crime prevention – KYC and account monitoring obligations under anti-money laundering regulations – Credit scoring and development or improvement of decisioning models – Transaction processing – Contract fulfillment and collections – Service improvement, training, research, analysis, and troubleshooting – Administration of the App or your account – Ensuring network and information security – Marketing and promotional offers
Photograph / image and personal appearance	– Identity verification – KYC obligations under anti-money laundering regulations
SMS logs and contents	– Fraud and crime prevention – Credit scoring and development or improvement of decisioning models
Location information	– Fraud and crime prevention – KYC and account monitoring obligations under anti-money laundering regulations – Credit scoring and development or improvement of decisioning models – Ensuring network and information security
Technical information, including the Internet Protocol (“IP”) address, the type of Device you use, unique device identifiers (for example, your Device’s “IMEI” or serial number), information about the mobile network provider and SIM card used by the Device, mobile network information, your Device’s operating system, the type of browser you use, the mobile applications installed on your Device, your Device’s technical specifications and settings	– Identity verification – Fraud and crime prevention – Credit scoring and development or improvement of decisioning models – Service improvement, training, research, analysis, and troubleshooting – Administration of the App or your account – Ensuring network and information security
Details of your use of the App, such as page interactions and navigation	– Identity verification – Fraud and crime prevention – Credit scoring and development or improvement of decisioning models – Service improvement, training, research, analysis, and troubleshooting – Administration of the App or your account – Ensuring network and information security
Communications with Tala or Tala’s service providers, including call recordings, inquiries, and service requests and tickets.	– Transaction and funds processing – Contract fulfillment and collections – Service improvement, training, research, analysis, and troubleshooting – Administration of the App or your account – Marketing and promotional offers
Credit information from credit reference agencies or the lender of record	– Identity verification – Fraud and crime prevention – KYC and account monitoring obligations under anti-money laundering regulations – Credit scoring and development or improvement of decisioning models – Service improvement, training, research, analysis, and troubleshooting
Transaction information from money service businesses, mobile network providers, payment and delivery service providers, collection agencies and analytics partners	– Identity verification – Fraud and crime prevention – KYC and account monitoring obligations under anti-money laundering regulations – Credit scoring and development or improvement of decisioning models – Service improvement, training, research, analysis, and troubleshooting

DISCLOSURE OF INFORMATION

Tala will not disclose any Personal Information to third parties unless it is necessary and/or appropriate in order to provide Tala’s products or services (provided, that, we may share de-identified data with select partners for research and development). Whenever practically feasible, Tala will only share your personal data with third parties in an anonymized or de-identified format.

Subject to Tala’s compliance with data storage localization requirements, we may provide read-only access to your information, including your Personal Information, where such access is necessary and customary to our business practices with certain third parties, including but not limited to any of Tala’s subsidiaries, affiliates, subcontractors, agents, service providers, or financing sources (including their or our employees, directors and officers) for the performance of any contractual obligation we may enter into with such parties or with you.

You understand and agree that Tala may, as necessary and/or appropriate for the purposes provided above, and likewise subject to Tala’s compliance with data storage localization requirements, transfer and disclose your Personal Information in identifiable form with:

• partner banks, non-banks, money service businesses, clearing houses, clearing or settlement systems, withholding agents, or other regulated entities and financial institutions (for purposes of KYC, account administration, credit disbursement, funds transfer, and loan repayment);
• credit reference agencies or credit bureaus (to obtain credit references and to comply with reporting requirements as applicable);
• external collection agencies (to assist in the collection of any unpaid obligations);
• service providers with contractual or fiduciary relationships with Tala (e.g., to facilitate transaction processing, debt collection, cloud data storage, business analytics);
• external counsel, external auditors, and consultants, when necessary to resolve disputes or complaints;
• a party in connection with any merger, acquisition or sale of all or substantially all of the assets of Tala and/or any company within the Tala Group;
• a party in connection with any assignment of credit or the creation of a security interest involving outstanding balances owned to Tala.

You agree and consent to receive all communications from Tala or from its authorized entities / third parties at the mobile number provided, even if this mobile number is registered under the National Customer Preference Register (NCPR) or National Do Not Call Registry (NDNC) list under Telecom Regulatory Authority of India (TRAI) regulations.

Further, Tala may also share your personal data with law enforcement or other government agencies in connection with a formal request, subpoena, court order, or similar legal procedure, or when we believe in good faith that disclosure is necessary to comply with the law, statutory or regulatory requirement; to prevent physical harm or financial loss; to report suspected illegal activity, or to investigate violations of our agreements with you.

MARKETING AND ANALYTICS

Tala may send you messages and emails carrying promotional materials and/or marketing surveys where you have provided your explicit consent to the same. To help Tala provide a user-friendly experience and improve the App and its Services, Tala and our third-party service providers, including our marketing partners and analytics providers, may use mobile tracking technologies and/or website cookies to distinguish you from other users of the App or Services. Analytics companies may also access anonymized individual data to help us develop and analyze the Services.

STORING YOUR INFORMATION

In compliance with data localization requirements under applicable regulatory guidelines, Tala commits to store Users’ Personal Information only in servers located within India. All data is encrypted in transit and is securely stored.

DATA RETENTION AND DISPOSAL

Tala will retain your information for as long as it is required to provide you with the Services, or while you are using our App. Retention periods for records are based on the type of information, the nature of the activity, and the product or service to which the same is associated.

The periods for retention of your information, including Personal Information, vary depending on specific legal business and statutory compliance. For example, in compliance with global anti-money laundering and counter financing of terrorism standards, Tala retains transaction data for a minimum period of seven (7) years from the transaction date. 

We may be required to retain your information post termination of our business relationship with you for fraud prevention purposes and for the exercises/defense of a legal claim or for providing evidence in legal proceedings.

Personal Information that is beyond the retention period shall be deleted or anonymized through globally recognized privacy measurement models, in accordance with Tala’s data retention and disposal policies. The method of deletion or anonymization ensures that disposal is done in a secure manner that would prevent re-identification or any further processing, unauthorized access, or disclosure.

RIGHTS OF USERS

You have certain rights related to the information we maintain about you and have the right to access the data records we maintain about you, including the right to obtain the details of how we process it.

You have the right to deny or revoke your consent from letting us access or process your Personal Information at any time, but this may render us unable to provide you with the Services. You may revoke your consent or request the deletion of your Personal Information, subject to Tala’s data retention obligations under applicable laws, by emailing us at dpo@tala.in. Tala reserves the right to require the settlement of loan balances prior to the fulfillment of such requests.

You have the right to correct or modify any information that has been provided to us or has been made available to us, subject to the presentation of relevant supporting documentation.

SECURITY OF INFORMATION

The transmission of information via the internet or mobile service is not completely secure. Tala cannot guarantee the security of your information transmitted by you or a third party in connection with the Services, and any such transmission is at your own risk. Once Tala has received your information, including Personal Information, we use and employ reasonable technical, organizational, logistical, physical and administrative measures to protect your information, against any unauthorized access, modification or use.

Tala implements an Information Security Management System to maintain the confidentiality, integrity, and availability of Tala’s information resources, in keeping with industry standard and global best practices. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Where Tala provides a password or PIN that enables you to access certain parts of the App or the Services, you are responsible for keeping this password or PIN confidential. In case of any failure to keep such password secure from your end, we shall not be held responsible.

In the event of a security breach involving a compromise to the availability, integrity and confidentiality of Personal Data, Tala implements an incident management policy to immediately ascertain the nature and extent of the incident, and to execute measures to mitigate the adverse effects of the incident

CHANGES & QUERIES

We retain the right to make changes to this Policy in future. We understand that it is our duty to keep you informed of any such changes, therefore the Policy with any such changes to it shall be posted on the App, and if required you will be notified via email or a notification on the App.

We advise you to go through our Policy diligently and periodically and accept any modifications prior to any continued use of the App or subsequent availing of our Services.

In case of any query or grievance pertaining to this Policy, you may contact us via mail for its redressal at dpo@tala.in. However, if you are not satisfied with the resolution of your concern, you may raise an escalation to the appointed Nodal Grievance Redressal Officer.

Tala – Nodal Grievance Redressal Officer:

Name: Mr. Arijit Ghosh

Email: grievance@tala.co.in

Number: 08046805888

The Nodal Grievance Redressal Officer will acknowledge all grievances within 48 hours of receipt and shall address them within a period of 30 days. 

LAST UPDATED ON: FEBRUARY 9, 2023