1.1 Soptle Technology Solutions Private Limited (Soptle) is engaged in the business of providing technology services and products to various merchants, in addition to certain data processing services/credit risk and other evaluations to Partner Banks and Non-Banking Financial Companies.
1.5 Under this Policy, we inform you regarding the manner in which we collect, store, use, disclose, transfer and process your Personal Information when you use our website, or avail any products or services which we may operate or offer to you either directly through our Websites or Platforms or through a merchant or partner platform; including the steps we take to protect your Personal Information.
2.1 “Personal information” means any information that relates to an individual, which directly or indirectly, in combination with other information available or likely to be available with us, is capable of identifying such individual. Such information may include information such as your mobile telephone number, email address, residential address, nationality, photo, employee ID number, tax identification number, Aadhaar number, personal identification proof (Driving License and/or passport), PAN number etc.
2.2 “Sensitive Personal Information” means any Personal Information of an individual, which consists of information relating to financial information such as bank account, credit card, debit card or other payment instrument details; and subject to the nature of the transaction and where permitted for diversity and monitoring purposes, we may collect information concerning your gender, information about your employment or marital status or personal characteristics, such as whether you are employed, place of work, and the number of days you work in a month etc.
2.3 However, information freely available or accessible in the public domain is not treated as Sensitive Personal Information. As a matter of principle, we do not collect certain special categories of Personal Information about you (such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, information about your health or any genetic and biometric information).
2.4 Depending on who you are (e.g., a merchant, customer, cardholder, consumer, supplier or business partner) and how you interact with us (e.g., through Website, Platform, telephone, IVR, online or offline), we may collect, use, receive, store, analyze, combine, transfer or otherwise process different categories of your Personal Information (including Sensitive Personal Information) whether directly:-
1. provided by you on an application to us or from data we collect from transactions you conduct using our services; or
3. from your financial institutions when you link your primary bank account to SOPTLE’s Services, we may collect several categories of your information, including Account information, including your financial institution’s name, the account type you use (such as a “checking account” or “savings account”), account number(s), and the institution’s routing number; Information about any balance or transactions in your account; and Information about the account owner(s), including name, email address, phone number, and mailing address information.
4. from other sources including our service providers. We currently use the following agencies to collect data:-
(i) Signzy Technologies Pvt Ltd
(ii) Karza Technologies Private Limited
(iii) Digiotech Solutions Pvt Ltd
(iv) CRIF High Mark Credit Information Services Pvt Ltd
(v) Experian Credit Information Company of India Pvt Ltd
3.1 Verification, Authentication, and Processing of Application purposes:
We process your Personal Information (including Sensitive Personal Information) for creating login credentials or establishing an account based relationship, doing KYC evaluation and risk assessments in order to authenticate and authorize your use of our products or services depending on if you are a merchant, consumer, borrower, service provider, or business partner, and your choice of services or products. The type of Personal Information (including Sensitive Personal Information) typically required is Identification Information, Identity, and Account Log-In Information, Contact Information and Financial Information. This is necessary to fulfill our legal obligations under certain applicable laws of India. To provide product/s or service/s made available by Soptle or the merchant or a third-party service provider, including financial institutions or in combination of all or any of the above.
3.2 To do internal risk assessments and analysis:
We may process your Personal Information (including Sensitive Personal Information) for the purposes of risk assessments and evaluations including or KYC checks, to improve our services, reduce fraud rates, build risk models, etc. We may also share such analysis with our business partners who may rely on the same to make decisions regarding whether to offer their products or services to you. Such analysis as described above does not usually utilize any Sensitive Personal Information about you and mostly your Personal Information is used for these purposes.
We use the information we collect to operate, improve, and protect the services we provide, and to develop new services. For example, we use your information to:
(i) provide SOPTLE’s Services;
(ii) improve, modify, add to, or further develop SOPTLE’s services;
(iii) protect you, SOPTLE’s service providers, or SOPTLE from fraud, malicious activity, or other privacy and security-related concerns;
(iv) provide customer service to you;
(v) investigate any misuse of SOPTLE’s Services;
(vi)develop new services.
5.1 The security of your Personal Information and Sensitive Personal Information is important to us. We take steps designed to protect your information that we collect, maintain, or disclose. These steps include maintaining information security controls, such as encryption technologies when transferring data or even when storing data, firewalls, and controls over the physical access to our systems. We regularly evaluate the security controls that we use, as well as the controls that our service providers use, for protecting the security and confidentiality of your information. Our goal is to maintain effective security controls, as measured by relevant industry standards or by independent security auditors, for all of the ways that you can use SOPTLE’s Services. We take all measures to prevent alteration, loss, or fraudulent or unauthorized access to your Personal Information (including Sensitive Personal Information). We have put in place procedures to deal with the breach of Personal Information and will notify you and any applicable regulator or authority of a breach where we are legally required to do so.
5.2 SOPTLE may keep your information for as long as necessary to fulfill the purpose for the information is collected. In addition, for some types of your information, SOPTLE may apply a longer retention period, such as for research or statistical analyses, except when storing or using that information for longer periods of time is not permitted under applicable law. As permitted under applicable law, even after you stop using the SOPTLE’s services or terminate your account with SOPTLE, we may retain your information.
We process Sensitive Personal Information only when we have obtained your consent in the manner provided hereinunder. For collecting, processing (including using and storing), disclosing, or sharing your Sensitive Personal Information as described in this Policy, we hereby through this Policy, seek your consent and give you notice regarding collecting, processing (including using and storing), and sharing your Sensitive Personal Information for one or more of the purposes detailed herein. For any purposes, where, as per applicable laws of India, a specific consent is required, we will seek such specific consent from you from time to time. In relation to information obtained from third parties or group entities, we rely on the consent taken herein in our favor for us to process the information. You may, of course, decline to share certain information with us, in which case we may not be able to provide to you some or all of the features and functionalities of the Websites and the Platform. This may also affect our ability to process your Personal Information (including Sensitive Personal Information) and may, therefore, lead to the non-availability or discontinuation of the services for which such Personal Information (including Sensitive Personal Information) is to be used or was being used, at our sole discretion.
Soptle makes various types of disclosures of your information to other persons as permitted by law. Our disclosures of your information may apply to some or all of the categories of your information that we collect. For example, Soptle may disclose all of the types of your information with your financial institution, consistent with your consent or instruction. Soptle also discloses, or reserves the right to disclose, your information:
(i) With Soptle’s service providers or contractors in connection with the services they perform for Soptle;
(ii) To the extent permitted by law, it will be necessary for us to verify the details you have supplied. Such verification could be done through third party service providers, who shall be bound by the obligation of confidentiality and data protection.
(iii) If Soptle believes in good faith that disclosure is appropriate to comply with applicable law, regulation, or legal process (such as a court order or subpoena);
(iv) In connection with a change in ownership or control of all or a part of Soptle’s business (such as a merger, acquisition, or bankruptcy);
(v) Between and among Soptle and Soptle’s future affiliates (such as subsidiaries or other companies under common control or ownership);
(vi) or With your consent (by any reasonable method, including when you orally give your consent), unless you timely revoke your consent.
We may collect, use, process, or disclose your information in an aggregated or anonymized manner (i.e., in a manner that does not identify you personally) for any purpose permitted under applicable law.
If you change your mind after opting-in, you may withdraw your consent to contact you, for the continued collection, use, or disclosure of your information, at any time, by mailing us at email@example.com or writing to us at the following address: [Fransisco Technology Pvt Ltd ,2nd floor , Plot Number 108, GoWork Building, Udyog Vihar Phase 1 , Gurgaon].
Soptle may update or modify this Policy from time to time. If we make material changes to this Policy, we will notify you by means of notice on Soptle’s website or as otherwise required by applicable law, including by e-mail or by posting the most current version of this Policy to the website. It is important that you review any changes to this Policy. If you do not agree with any changes to this Policy, you may not use Soptle’s services. Your continued use of Soptle’s services after the changes have been implemented shall be deemed to constitute your acceptance of the changes.
Last updated: [04/09/2023]
1. Tyke2. BlackSoil