This Privacy Policy document (“Privacy Policy”) is published in accordance with the provisions of Rule 4 (1) of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 which requires the publishing of a privacy policy for handling of or dealing in personal information including sensitive personal data or information.

This website asapfinance.in is owned and operated by Cieco Securities Private Limited (herein after referred to as “Company” or “Cieco”) having its principal place of business at E-25/A, Hauz Khas Main Market Lane, Hauz Khas, New Delhi - 110016 (which expression shall mean and include its affiliates, successors and permitted assigns). Cieco is committed to protecting and respecting the privacy of its customers. Any person who enters or uses this website or shares information on this website or through our mobile application is considered as customer (“user” or “you” or “your”) for the purpose of this policy. If you do not agree to this Policy or any part thereof, please do not use/ access/ download or install the Platform or any part thereof.

In the course of using this website or availing the products and services vide the online application forms and questionnaires, Cieco may become privy to the personal information of its customers, including information that is of a confidential nature. However, the Company is strongly committed to protecting the privacy of its customers and has taken all necessary and reasonable measures to protect the confidentiality of the customers information and its transmission through the World Wide Web. Cieco shall not be held liable for disclosure of the confidential information if such disclosure is in accordance with this Privacy Policy or in accordance with the terms of any agreements entered into with the customers or required under any Statute or Regulation.

Collection of information

During the use of this website or our mobile application, Cieco may collect and process such text and media information, including but not limited to the below mentioned :-

• Information that the customers provide to Cieco by filling in forms on the website / mobile application or in any other mode. This includes contact information such as name, email address, employment and residence address, phone number etc;
• Documents / images that the customers share by submission / upload to the Cieco server/s in the process of submitting an application on the website / mobile application or in any other mode. This includes personal photograph / selfie of customer, identity verification documents like PAN / Aadhaar, valid address proofs, income verification documents like bank account statements / payslips /other employment proofs etc. Cieco seeks permission for Camera and Phone Storage to enable users to take selfie and upload images/ documents required in the course of loan application;
• Information that the customers provide when the customers write directly to Cieco (including by way of e-mail);
• Information that the customers provide to Cieco over telephone. Cieco may make and keep a record of the information shared by the customers with Cieco;
• Information that the customers provide to Cieco by completing surveys;
• Cieco accesses the SMS log of customers’ mobile phone and reads only the non-personal SMS sent by 6-digit or 4-digit alphanumeric senders to authenticate the user identity and verify the account and further to analyse the nature of financial transactions from various bank accounts of the customer to arrive at an estimate of the income/ expenses pattern, cash flow analysis and perform a credit risk assessment on him/ her and provide him/ her with a loan offer. We do not read or collect any personal SMS of customers;
• Cieco seeks permission for location to collect and monitor the information about the location of customer’s device to provide serviceability of loan application, to reduce risk associated with the loan application and to provide pre-approved customised loan offers. This also helps us to facilitate verification of the address, making a better credit risk decision and know your customer (KYC) process;
• Cieco also collects information about customer’s device that includes hardware model, build model, RAM, storage, unique device identifiers like IMEI, serial number, SSAID, AAID, SIM information that includes network operator, roaming state, MNC and MCC codes, WIFI information that includes MAC address and mobile network information to uniquely identify the devices and ensure that no unauthorized device acts on customer’s behalf to prevent frauds. Cieco seeks permission of user’s phone state so that same may be used in digital transactions and relate the same with the identity of the customer;
• Information that Cieco collects through its mobile application or wesbite depends on how the customers manage/ allow their permissions that our mobile App seeks explicitly from customers. There is no unauthorised access of information of customer by Cieco at any point of time. In addition to the above, Cieco also tracks and collects data related to the performance of the mobile app and other diagnostic data for identifying and resolving any technical glitches that may be identified from such data and also for improving the overall functionality of its mobile applications.

Non-disclosure

Cieco pledges that it shall not sell or rent customers’ personal details to anyone. Cieco shall protect every bit of the customers’ business or personal information and maintain the confidentiality of the same. Cieco undertakes to keep all information confidential except in the following cases :-

• Cieco may disclose customers’ information to governmental and other statutory bodies who have appropriate authorization to access the same for any specific legal purposes;
• Cieco may disclose customers’ information if it is under a duty to do so in order to comply with any legal obligation, or in order to enforce or apply the terms & conditions displayed on the website or such other documents or electronic communication as may be signed/ agreed-to by the customer, or to protect the rights, property or safety of Cieco, its customers or others. This includes exchanging information with other companies / agencies that work for fraud prevention and credit reference / information sharing;
• Cieco may disclose customers’ information to such third parties to whom it transfers its rights and duties under the customer agreement entered into with the customers. In such an event, the said third parties’ use of the information will be subject to such confidentiality obligations as contained in this Policy;
• Cieco may disclose customers’ information to any member of its related or group companies including its subsidiaries, its ultimate holding Company and its subsidiaries, as the case may be;
• In the event that Cieco sells or buys any business or assets, it may disclose the customers’ information to the prospective seller or buyer of such business or assets. Customer's email and visitor information is generally one of the transferred business assets in these types of transactions. Cieco may also transfer or assign such information in the course of corporate divestitures, mergers or dissolution.

Cieco Securities Private Limited will never sell or rent personal information of its clients to anyone, at any time, for any reason.

Cieco may use the customer’s personal information in the following ways, viz :-

• Monitor, improve and administer the website and improve the quality of services;
• Analyze how the website is used, diagnose service or technical problems, maintain security;
• Remember information to help the customers effectively access the website;
• Monitor aggregate metrics such as total number of views, visitors, traffic and demographic patterns;
• To confirm the Customer’s identity in order to determine its eligibility to use the website and avail of the services;
• To notify the customers about changes to the website;
• To enable Cieco Securities Private Limited to comply with its legal and regulatory obligations;
• To help the customers apply for certain products and services;
• For the purpose of sending administrative notices, service, related alerts and other similar communication with a view to optimizing the efficiency of the website;
• Doing market research, troubleshooting, protection against error, project planning, fraud and other criminal activity;
• To reinforce any terms or conditions under the documents signed by the customer and Cieco Securities Private Limited or electronic communications between customer and Cieco Securities Private Limited or any notices (or other form of written correspondence) between customer and Cieco Securities Private Limited.

Security of information

Cieco takes the security of its customer’s information very seriously. Cieco protects the customer’s information using 128 bit-encryption and a Secure Sockets Layer (SSL) protocol. This creates an encrypted connection between the customer’s browser and Cieco’s servers. All information remains encrypted at all times.

All information provided to Cieco is stored on its secure servers.

Cieco uses commercially reasonable safeguards to preserve the integrity and security of the customers’ information against loss, theft, unauthorized access, disclosure, reproduction, use or amendment.

The information that is collected from the customers may be transferred to, and stored at, any place within India in our cloud or physical servers at all times. By submitting information on the website/or though other physical or electronic form, the customers agree to this transfer, storing and / or processing. Cieco will take such steps as it considers reasonably necessary to ensure that the customers’ information is treated securely and in accordance with the Policy.

In using the website, the customers accept the inherent security implications of data transmission over the internet and the World Wide Web cannot always be guaranteed as completely secure. Therefore, the use of the website will be at the own risk of the customers.

Cieco assumes no liability for any disclosure of information due to errors in transmission, unauthorized, third party access or other acts of third parties, or acts or omissions beyond its reasonable control and the customers agrees not to hold Cieco responsible for any breach of security unless such breach has been caused as a direct result of gross negligence or wilful default by Cieco.

In the event Cieco becomes aware of any breach of the security of the customers’ information, it will promptly notify the customers and take appropriate action to the best of its ability to remedy such a breach.

Exclusion

This Policy does not apply to any information other than information collected by Cieco Securities Private Limited through the website including such information collected in accordance with the clause on “Collection of Information” above. This Policy shall not apply to any unsolicited information provided by the customers through this website or through any other means. This includes, but is not limited to, information posted to any public areas of the website. All such unsolicited information shall be deemed to be non-confidential and Cieco Securities Private Limited shall be free to use, disclose such unsolicited information without limitation. Any customer aggrieved with the policy or its implementation or contents relating to information may approach the Grievance Officer for redressal of his grievance.

Referrals

If the customer wishes to introduce Cieco / the website to any other person / entity, the customers will be asked to provide such person / entity’s name and email address. Cieco may send such person / entity an email inviting it or to visit the website. Cieco may store this information for the purpose of sending this email and keeping a record of the number of persons / entities so referred by the customers. Cieco may send additional emails to the said person / entity in connection with services offered by Cieco. Such person / entity may contact Cieco at the address / email ID provided below on Grievance Redressal Officer, to request that this information be removed from Cieco’s database.

The website includes Social Media Features, such as the Facebook “Like” button and Widgets, or interactive mini-programs that run on the website. These features may collect the customers’ IP address, which page the customers are visiting on the website, and may set a cookie to enable the feature to function properly. Social Media Features and widgets are either hosted by a third party or hosted directly on the website. The customers’ interactions with these features are governed by the privacy policy of the Company providing it.

Opting In

Cieco may use the customer’s contact information like email address and mobile number for the purpose of disseminating important information about the company and/ or its latest product offerings in the interest of customers from time to time. Every customer shall be provided with an Opt-in/ out option at the time of login to our website and/ or mobile application towards availing such future services free of cost. Every customer shall have the right to exercise his/ her option to Opt-out from such services of the company. Wherein any customer has Opt-out of the services, no such communication shall be made to customer in the future.

Opting out or editing customer information

To opt out of email correspondence from Cieco or make a change to (or delete) the customers information stored in Cieco’s records, customer may send his / her request by way of email to info@asapfinance.in

Data retention and Deletion

Customer’s information shall be retained for as long as needed to provide services to the customers. Cieco retains and uses customer information as necessary to provide seamless experience, to detect, mitigate, prevent, and investigate fraudulent or illegal activities during the services, to comply with its legal obligations, resolve disputes, and enforce its agreements. For customers who have availed any loan from Cieco, the Company shall maintain all such records of transactions with the customer for a minimum period of five years from the date of commencement of the loan transaction, in terms of the Prevention of Money Laundering Amendment Act 2012 and/ or any other regulatory guidelines from time to time. Subject to this section, Cieco shall delete any Customer data/ account upon reasonable written request at info@asapfinance.in for the same at any stage. However, customer may not be able to use our services after deletion of his account.

Updates

In the event Cieco Securities Private Limited modifies this Privacy Policy, the same will be updated on the website. The customers are encouraged to periodically review this page for the latest information on privacy practices.

Severability

Cieco Securities Private Limited has made every effort to ensure that this Policy adheres with the applicable laws. The invalidity or unenforceability of any part of this Policy shall not prejudice or affect the validity or enforceability of the remainder of this Policy.

No waiver

The rights and remedies available under this Policy may be exercised as often as necessary and are cumulative and not exclusive of rights or remedies provided by law. It may be waived only in writing. Delay in exercising or non-exercise of any such right or remedy does not constitute a waiver of that right or remedy, or any other right or remedy.

Governing law

This Policy shall be governed by and construed in accordance with the laws of India and subject to the provisions of arbitration set out herein, the courts at Delhi shall have exclusive jurisdiction in relation to any disputes arising out of or in connection with this Policy.

If any dispute arises between Cieco and the customers in connection with or arising out of the validity, interpretation, implementation or alleged breach of any provision of the Policy, such dispute shall be referred to and finally resolved by arbitration in accordance with the Indian Arbitration and Conciliation Act, 1996 for the time being in force, which rules are deemed to be incorporated by reference in this clause.

There shall be one (1) arbitrator and the seat of the arbitration shall be Delhi, India. The language of the arbitration proceedings and of all written decisions and correspondence relating to the arbitration shall be English.

Foreign jurisdiction

Cieco Securities Private Limited makes no representation that the content contained on the website is appropriate or to be used or accessed outside of the India. If the customers use or access the website from outside the India, they do so at their own risk and are responsible for compliance with the laws of such jurisdiction.

Contact

In case of any questions or concerns, the customer may contact the Customer Care department of the Company at the below co-ordinates:- ………………………., mail: info@asapfinance.in

In case the customer is not satisfied with the response / resolution provided by the Customer Care department in the normal course of business, he / she may contact the Grievance Redressal Officer of the Company with his / her unresolved queries / concerns at the below co-ordinates :

Name: Mr. Vivek pachori
Mobile: +91-7314903803
Email: vivek.pachori@ciecosecurities.com

After examining the matter, it shall be our endeavor to provide the customer with our final response, within a period of one (1) month from thereceipt of such query / concern.

In order to enhance the value and relevance to the borrowers, this Privacy Policy shall be under review from time to time.

Cieco Securities Private Limited is a Non Banking Finance Company (NBFC) registered with the Reserve Bank of India (RBI). is the brand name under which the company conducts its lending operations and specialises in meeting customer’s instant financial needs.

Corporate Identity No. (CIN): U65993DL1992PTC457791

RBI Certificate of Registration No (CoR): B.05.06060

Registered Office: E-25/A, First Floor, Hauz Khas Main Market parking, Hauz Khas, New Delhi - 110016