Privacy Policy
1. INTRODUCTION
Madhuri Holdings Limited (“Madhuri Holdings”, “Company”, “we”, “us” or “our”) is a Non-Banking Financial Company (“NBFC”) engaged in providing financial and lending services to eligible customers.
This Privacy Policy explains how Madhuri Holdings collects, receives, uses, processes, stores, shares and protects personal information of customers, prospective customers, applicants, borrowers, website visitors and other individuals who interact with us through our website, mobile applications, digital lending platforms, loan application processes, customer service channels or other means.
This Privacy Policy is intended to provide transparency regarding our data practices and to comply with applicable laws, regulations and regulatory directions, including applicable requirements of the Reserve Bank of India (“RBI”) and applicable data protection and privacy laws in India.
By using our website, application or services, or by voluntarily providing information to us, you acknowledge that you have read and understood this Privacy Policy.
2. SCOPE OF THIS POLICY
This Privacy Policy applies to personal information collected through:
• Our website and web applications;
• Loan application and onboarding processes;
• KYC and verification processes;
• Customer service and grievance channels;
• Loan servicing, repayment and collection activities;
• Communications through email, SMS, WhatsApp or other permitted channels;
• Our authorised Lending Service Providers (“LSPs”) and technology/service partners, where applicable; and
• Offline or physical interactions with our customers.
This Policy does not apply to third-party websites, applications or services that are not owned or controlled by Madhuri Holdings. Such third parties may have their own privacy policies.
3. INFORMATION WE COLLECT
Depending upon the nature of the service and applicable legal requirements, we may collect the following categories of information.
3.1 Identity and KYC Information
• Full name;
• Date of birth;
• Photograph;
• Gender, where required;
• PAN;
• Aadhaar or other officially valid documents;
• Address and proof of address;
• Identity verification information;
• KYC and video-KYC information, where applicable;
• Signature and other information required for customer verification.
KYC information may be collected and verified in accordance with applicable RBI KYC requirements and other applicable laws.
3.2 Contact Information
• Mobile number;
• Email address;
• Residential address;
• Correspondence address;
• Employment/business contact information; and
• Other contact details provided by you.
3.3 Financial and Banking Information
• Bank account details;
• Account holder name;
• Bank statements or financial statements;
• Income and salary information;
• Employment/business information;
• Existing loan and repayment obligations;
• Transaction-related information;
• Repayment and mandate information; and
• Other financial information necessary for providing our services.
3.4 Credit Information
Where permitted by law, we may obtain information from Credit Information Companies (“CICs”), credit bureaus and other authorised sources.
This information may include credit score, credit history, existing loans, repayment history, outstanding liabilities, credit enquiries and other information available from authorised credit information providers.
Such information may be used for credit assessment, underwriting, fraud prevention, loan servicing and regulatory purposes.
3.5 Device and Technical Information
When you use our digital platforms, we may collect limited technical information necessary for security, fraud prevention, application functionality and performance, including IP address, device type, operating system, application version, browser information, device identifiers, network information, login information, date/time of access and security/diagnostic information.
We will not access device information merely because it is technically available. Data access will be limited to what is necessary and permitted for the relevant purpose.
3.6 Information Relating to Loan Applications
We may collect information relating to loan amount requested, loan purpose, employment/business details, income, repayment capacity, existing financial obligations, loan documents, references or other information where lawfully required, application status and information generated during the credit assessment process.
4. INFORMATION WE DO NOT COLLECT UNNECESSARILY
Madhuri Holdings follows a need-based approach to data collection.
We do not seek access to personal information merely because such access is technically possible.
Unless specifically required and legally permitted for a particular purpose, we do not seek unnecessary access to contact lists, call logs, personal photographs, personal files, SMS messages, microphone, camera, location information or other device resources.
Where access to any particular information or device permission is required for a specific service or legally mandated process, we will provide appropriate information and obtain the required permission/consent, wherever applicable.
5. PURPOSES FOR COLLECTING AND USING PERSONAL INFORMATION
We may process personal information for the following purposes:
5.1 Customer Onboarding and KYC
• Customer identification;
• KYC verification;
• Customer due diligence;
• AML/CFT compliance;
• Fraud prevention;
• Regulatory reporting; and
• Legal compliance.
5.2 Loan Processing
• Receiving and processing loan applications;
• Assessing eligibility;
• Credit underwriting;
• Determining repayment capacity;
• Credit scoring and risk assessment;
• Approving or declining loan applications;
• Preparing sanction documentation;
• Executing loan agreements; and
• Disbursing loans.
5.3 Loan Servicing
• EMI/repayment processing;
• Account management;
• Statements and transaction records;
• Payment reminders;
• Customer support;
• Foreclosure and closure requests;
• NOC issuance;
• Security instrument management; and
• Other loan servicing activities.
5.4 Fraud Prevention and Security
• Detect and prevent fraud;
• Detect suspicious transactions;
• Prevent identity theft;
• Protect our systems;
• Investigate security incidents;
• Prevent misuse of our services; and
• Protect customers and the Company.
5.5 Regulatory and Legal Compliance
We may process information where required for RBI requirements, KYC/AML requirements, credit bureau reporting, tax requirements, court/regulatory/governmental orders, audit and inspection, dispute resolution and other statutory or regulatory obligations.
6. CREDIT ASSESSMENT AND AUTOMATED PROCESSING
Madhuri Holdings may use technology, rules-based systems, statistical models, credit assessment tools and other automated or technology-assisted processes for credit assessment, risk assessment, fraud detection, customer verification, loan eligibility assessment and operational decision-making.
Such processes may consider information provided by the applicant and information obtained from authorised and lawful sources.
Where applicable law provides rights relating to automated decision-making or requires human intervention, Madhuri Holdings will comply with such requirements.
7. CONSENT
Where consent is required under applicable law, Madhuri Holdings will obtain consent through appropriate electronic, written or other lawful mechanisms.
Consent may be requested separately for different purposes where required.
You may withdraw consent where the applicable law permits such withdrawal.
However, withdrawal of consent may affect our ability to provide certain services where the relevant processing is necessary for providing the service, complying with a legal obligation, preventing fraud or fulfilling another lawful purpose.
Withdrawal of consent will not affect the lawfulness of processing undertaken before withdrawal.
8. SHARING OF PERSONAL INFORMATION
Madhuri Holdings may share personal information only where necessary and permitted under applicable law.
Information may be shared with:
8.1 Regulatory and Government Authorities
Reserve Bank of India, Government authorities, regulatory authorities, law enforcement agencies, courts and tribunals, tax authorities and other legally authorised authorities.
8.2 Credit Information Companies
Relevant information may be submitted to or obtained from authorised Credit Information Companies in accordance with applicable law and regulatory requirements.
8.3 Lending Service Providers and Technology Partners
We may engage authorised Lending Service Providers, technology providers, KYC providers, credit assessment providers, payment service providers, collection service providers and other vendors to support our lending operations.
Such parties will be permitted to process customer information only for authorised purposes and subject to appropriate contractual, confidentiality, security and regulatory requirements.
Madhuri Holdings remains responsible for compliance with applicable regulatory requirements relating to activities undertaken on its behalf.
8.4 Banks and Payment Service Providers
Information may be shared with banks, payment gateways, payment service providers, mandate providers and other authorised entities where required for loan disbursement, EMI/repayment collection, electronic mandates, payment processing, refunds or related financial transactions.
8.5 Professional Advisors
Information may be shared with auditors, lawyers, consultants and professional advisors where reasonably necessary and subject to confidentiality obligations.
8.6 Corporate Transactions
In the event of a merger, restructuring, acquisition, transfer of business or assets or similar corporate transaction, personal information may be transferred where legally permitted and subject to appropriate safeguards.
9. DATA SECURITY
Madhuri Holdings takes reasonable technical and organisational measures to protect personal information against unauthorised access, unauthorised disclosure, loss, misuse, alteration, destruction and other unlawful processing.
Security measures may include access controls, authentication mechanisms, encryption or other appropriate safeguards, monitoring, logging, vulnerability management and periodic security reviews, as appropriate to the nature of the information and risks involved.
Access to customer information will be restricted to authorised personnel and service providers who have a legitimate business or legal need to access such information.
10. DATA STORAGE
Madhuri Holdings will store and process personal information in accordance with applicable law and RBI requirements.
For digital lending operations, customer data will be handled in accordance with applicable RBI requirements relating to data storage, security, access and processing.
Where third-party service providers are engaged, Madhuri Holdings will take appropriate contractual and operational measures to ensure that customer information is handled in accordance with applicable requirements.
11. DATA RETENTION
We retain personal information only for as long as reasonably necessary for providing our services, maintaining loan and customer records, fulfilling contractual obligations, complying with legal and regulatory requirements, meeting RBI/KYC/AML and credit reporting requirements, resolving disputes, preventing fraud and enforcing our legal rights.
After the applicable retention period expires, information may be securely deleted, anonymised or otherwise disposed of in accordance with applicable law and our internal policies.
12. COOKIES AND SIMILAR TECHNOLOGIES
Our website and digital platforms may use cookies and similar technologies for website functionality, security, session management, analytics, performance monitoring and improving user experience.
Where required, we will provide appropriate information and obtain consent for cookies or similar technologies.
You may be able to control cookies through your browser or device settings. Disabling certain cookies may affect the functionality of our website.
13. MARKETING COMMUNICATIONS
Where permitted by applicable law, Madhuri Holdings may communicate with customers regarding products, services, offers or relevant information through SMS, email, telephone, WhatsApp, push notifications or other permitted communication channels.
Customers may opt out of promotional communications through the available unsubscribe or opt-out mechanism.
Transactional, regulatory, security, loan servicing and legally required communications may continue even after opting out of promotional communications.
14. THIRD-PARTY LINKS AND SERVICES
Our website, application or communications may contain links to third-party websites or services.
Madhuri Holdings is not responsible for the privacy practices, content or security of third-party websites.
Customers are advised to review the privacy policies of such third parties before providing personal information.
15. CUSTOMER RIGHTS
Subject to applicable law and prescribed procedures, customers may have rights relating to their personal information, including rights to obtain information regarding processing of personal data, request correction or updating of inaccurate information, request deletion where legally permissible, withdraw consent where processing is based on consent, raise a grievance regarding processing and exercise other rights available under applicable law.
Certain requests may not be capable of being fulfilled where retention or processing is required by law, regulation, court order, fraud prevention requirements or other lawful purposes.
16. HOW TO EXERCISE YOUR RIGHTS
Customers may contact Madhuri Holdings using the contact details provided in this Privacy Policy to request access to personal information, request correction, raise a privacy-related grievance, withdraw consent where applicable or seek clarification regarding processing of personal information.
We may require reasonable verification of the applicant’s identity before processing a request.
17. GRIEVANCE REDRESSAL
If you have any concern regarding the collection, use, storage, sharing or processing of your personal information, you may contact our Grievance Officer.
Grievance Officer
Name: Sachin Sharma
Designation: Grievance Redressal Officer
Email: gro@madhuriholdings.com
Telephone: 011-41648566
Address: E20, South Extension I, Delhi 110049
We will endeavour to acknowledge and resolve privacy-related grievances within the period prescribed under applicable law and regulatory requirements.
For loan-related grievances, customers may also follow the grievance redressal mechanism provided in our loan documents and on our website/application.
18. DATA BREACH AND SECURITY INCIDENTS
In the event of a data security incident or personal data breach, Madhuri Holdings will take appropriate steps to investigate the incident, contain and mitigate the impact, secure affected systems, assess the nature and extent of the incident, notify relevant authorities where required by law and notify affected individuals where required by applicable law.
19. CHILDREN’S DATA
Our lending services are intended for eligible adults.
We do not knowingly collect personal information from children where such collection is prohibited by applicable law.
If we become aware that personal information has been collected contrary to applicable legal requirements, we will take appropriate steps as required by law.
20. CONFIDENTIALITY OF CUSTOMER INFORMATION
Madhuri Holdings recognises the confidential nature of customer information.
Customer information will not be sold or commercially exploited in a manner inconsistent with applicable law or this Privacy Policy.
Customer information may, however, be disclosed where necessary for legitimate business purposes, loan processing, credit reporting, service delivery, fraud prevention, regulatory compliance, legal requirements or other lawful purposes described in this Policy.
21. INTERNATIONAL DATA TRANSFERS
Where personal information is processed, stored or accessed outside India through an authorised service provider, Madhuri Holdings will ensure that such processing is undertaken in accordance with applicable law, RBI requirements and appropriate contractual and security safeguards.
Nothing in this clause permits any processing or transfer that is prohibited by applicable law or regulatory directions.
22. CHANGES TO THIS PRIVACY POLICY
Madhuri Holdings may update this Privacy Policy from time to time to reflect changes in applicable laws, RBI regulatory requirements, changes in our products or services, changes in technology or changes in our data processing practices.
The updated Privacy Policy will be published on our website/application with the revised “Last Updated” date.
Where required by law, material changes will be communicated to customers through appropriate means.
23. GOVERNING LAW
This Privacy Policy shall be governed by and interpreted in accordance with the laws of India.
Any dispute relating to this Privacy Policy shall be subject to the applicable jurisdiction of the competent courts and authorities in India, subject to applicable law.
24. CONTACT US
Madhuri Holdings Limited
Registered Office: E20, Basement, South Extension I, Delhi 110049
Email: info@madhuriholdings.com
Customer Care: 8882516092
Privacy/Grievance Email: gro@madhuriholdings.com
Grievance Officer:
Name: Mr. Sachin Sharma
Designation: Grievance Redressal Officer
Email: gro@madhuriholdings.com
Contact No.: 011-41648566
25. CUSTOMER ACKNOWLEDGEMENT
By accessing our website, application or services and/or submitting information to Madhuri Holdings Limited, you acknowledge that you have read and understood this Privacy Policy.
Where applicable, your consent will be obtained separately through appropriate consent mechanisms before processing personal information for purposes requiring consent.
Madhuri Holdings Limited
