This privacy policy (“Privacy Policy”) establishes the terms and conditions under which Venus Barter Private Limited (“the Company” or “VenusBarter” or “we” or “us” or “our”) with registered address at 71, Metcalfe Street 3rd Floor, Room No- 302, Kolkata, Kolkata, West Bengal, India, 700013., processes the personal information that you provide us with when using the website “www.venusbarter.in” (“the Website” or “site”) and other related internet based applications designed to be used on smart phones, tablets or other mobile devices (“App”) or other applications, software, digital media, storage medium, or functionalities related to our brand (collectively referred to as “Platform”).
This Privacy Policy gives you details about our data collection methods and usage. Users, please take note that any statements made on the Platform shall not be construed as an offer or promises for grant of any financial services.
Maintaining the security of your data is a priority at VenusBarter. We are committed to respecting your privacy rights. We pledge to handle your data fairly and legally at all times. We are also dedicated to being transparent about what data we collect about you and how we use it. By visiting and accessing the Platform and availing the loan services provided by us, you are deemed to have read, acknowledged and accepted all the provisions stated here in the Privacy Policy, including any changes we may make from time to time.
By assenting to this Privacy Policy, you consent explicitly to the collection, use, processing, retention and disclosure of your Personal Information that you provide to the Company. This Privacy Policy is incorporated into and subject to the Terms and Conditions of the Platform. You are providing the Personal Information out of your free will and with informed consent.
In this Privacy Policy, “Personal Information” means information provided by you that can be used to directly or indirectly identify you including through your mobile number or email address, either from that information alone or from that information combined with other information the Platform has/may have access to about you. Such Personal Information may include your name, email address, date of birth, residence address, telephone number, your financial information, device information, identity information and/or location information.
If you do not agree to this Privacy Policy or any part thereof, please do not use/ access/ download or install the Platform or any part thereof.
The Platform is not expected to be used by any person below 18 years of age.
This Privacy Policy provides you with information about:
1 What Personal Information We Collect
1.1 We will only collect information that is necessary and needed for the specified, explicit and lawful purposes of rendering our services and will not further process it in a manner that is incompatible with those purposes. We may collect the following types of information:
1.1.1 Information you provide to us or upload on our Platform including your contact information (eg.: name, date of birth, gender, photo, postal or e-mail address, fax number, phone number, education, occupation, account details, identification documents, banking information such as salary slips, bank statements, PAN card, bank account number, payment information, or any other information/documents for KYC compliance).
1.1.2 Information from credit bureaus and customer service providers to help VenusBarter with customer verification and diligence required for VenusBarter and partners.
1.1.3 Location: We collect and monitor the information about the location of your device to check serviceability of your loan application, prevent fraudulent activity and also provide customised loan offers.
1.1.4 Social Media: We collect your public profile data depending on the social media or networking platform used like Facebook/LinkedIn etc. to login to our Platform. The information collected from your social media networking account shall be clearly displayed to you at the time of login to our Platform.
1.1.5 Financial information: We may collect information related to your transactions on the Platform such as loan details, transaction history, and repayment details.
1.1.6 Details required for administration or services and product improvement.
1.1.7 Feedback given by you.
1.2 This list is not exhaustive and, in specific instances we may need to collect additional data for the purposes set out in this Privacy Policy. However, one time access may be required for camera, microphone, location or any other facility necessary for the purpose of on-boarding/ KYC requirements.
1.3 We may collect other types of Personal Information in exceptional circumstances only. If we do need to process additional types of Personal Information about you, we will make sure that you are informed about the processing of your Personal Information and that there is a valid legal basis for doing so (e.g. your consent).
2 Collection of Personal Information and Processing Purposes
2.1 Please bear in mind that before availing any services on the Platform, you must read this Privacy Policy. You may choose not to provide certain Personal Information or withdraw the consent or ask us to delete such information collected or restrict disclosure to third parties subsequently with respect to such Personal Information by sending a written intimation. However, not providing certain compulsory information or withdrawing the consent may mean that it will not be possible to manage your registration as a user or to use certain functionalities available through the Platform.
2.2 You hereby guarantee that the Personal Information provided is true and exact, and agree to report any change or modification thereto. If you provide us with the Personal Information of third parties, you shall be responsible for having informed them and obtained their consent for these details to be provided for the purposes indicated in the corresponding provisions of this Privacy Policy. Any loss or damage caused to the Platform, to Company or to any third party through the communication of erroneous, inaccurate or incomplete information on the registration forms shall be your sole responsibility.
2.3 The Personal Information provided by you will be collected and retained, on behalf of our Lending Partner.
2.4 You hereby consent that we may process and disclose Personal Information to our affiliates, third party service providers and credit bureaus for the purposes stated in this Privacy Policy.
2.5 The Company shall use the Personal Information for the following purposes:
2.5.1 To provide products you have requested;
2.5.2 To provide services you have requested;
2.5.3 To provide information to our partners to assist in making, credit decisions about you;
2.5.4 To help investigate violations of our terms of use or to defend against legal claims;
2.5.5 To disclose the information under special circumstances such as compliance with the applicable local law, court summons, court orders, requests/order from legal authorities or law enforcement agencies requiring such disclosure;
2.5.6 Search credit bureaus and fraud prevention agencies;
2.5.7 To get in touch with you when necessary and contact you by email, SMS, letter, telephone or in any other way about our products and services;
2.5.8 To identify, prevent, detect or tackle fraud, money laundering, terrorism and other crimes;
2.5.9 To form a view of you as an individual and to identify, develop or improve products, that may be of interest to you;
2.5.10 Provide information to independent external bodies such as governmental departments and agencies, universities and similar to carry out research;
2.5.11 Perform other administrative and operational purposes including the testing of systems;
2.5.12 Trace your whereabouts;
2.5.13 Recover any payments you owe to VenusBarter or partners; and
2.5.14 Comply with our regulatory obligations;
2.5.15 To show you advertisements;
2.5.16 Contact you as a survey respondent;
2.5.17 To maintain records under applicable law or a may apply to pursuant to agreements executed by VenusBarter;
2.5.18 Carry out, monitor and analyse our business, carry out market research, business, and statistical analysis and also direct our efforts for product improvement;
2.5.19 Carry out audits;
2.5.20 Collecting user feedback. The feedback you choose to provide is valuable in helping the Platform make improvements to our services. In order to follow up on the feedback that you choose to provide, the Platform may correspond with you using the Personal Information that you have provided and may keep records of the same.
2.5.21 Sending notices. From time to time, we may use your Personal Information to send important notices, such as communications about changes to our terms, conditions and policies.
2.6 We may disclose your Personal Information:
2.6.1 to companies that are affiliated with us.
2.6.2 to third-party service providers who provide services to VenusBarter, such as sourcing of customer, loan recovery services, website hosting, data analysis, payment processing, infrastructure provision, information technology services, due-diligence, customer service, e-mail delivery services, credit card processing, auditing, training, and other similar services. (These third parties will be supplied with, or have access to, your Personal Information for the purpose of providing these services to us or on our behalf).
2.6.3 to the administrators. We might provide your Personal Information to our management team or administration department to enhance your experience with us and assist you 24*7.
2.6.4 to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
2.6.5 as we believe necessary or appropriate: (i) under applicable law, including laws outside your country of residence; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (iv) to enforce Terms and Conditions of the Platform; (v) to credit information companies (vi) to protect our operations or those of any of our affiliates; (vii) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (viii) to allow us to pursue available remedies or limit the damages that we may sustain.
3 How We Protect Your Personal Information
3.1 All your Personal Information is stored on secure servers that are protected in controlled facilities situated in India. We classify your data based on importance and sensitivity, and ensure that your Personal Information has the highest security level. We maintain appropriate technical and organizational security safeguards designed to protect the Personal Information we process against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use including adopting reasonable security practices and procedures comprising of managerial, technical, operational and physical security control measures as mandated under applicable Indian laws for the protection of Personal Information and to prevent unauthorised use or disclosure of Personal Information.
3.2 When you send or receive data from your device to our servers, we make sure they are encrypted using Secure Sockets Layer (“SSL”) and other algorithms.
3.3 We will take all practicable steps to safeguard your Personal Information. However, you should be aware that the use of the internet is not entirely secure, and for this reason we cannot guarantee the security or integrity of any Personal Information which is transferred from you or to you via the internet.
4 How Long We Retain Personal Information
4.1 Personal Information will be held for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. We shall cease to retain Personal Information, or remove the means by which the Personal Information can be associated with particular individuals, as soon as it is reasonable to assume that the purpose for which that Personal Information was collected is no longer being served by retention of the Personal Information, and there being no outstanding payment obligations of you towards the Lender.
5 Updates to the Privacy Policy
5.1 We keep our Privacy Policy under regular review and may update this Privacy Policy to reflect changes to our information practices. If we make any changes to our Privacy Policy, we will post the changes on the Platform so that you may be aware of the information we collect and how we use it. Such changes to our Privacy Policy shall apply from the effective date as set out in the notice or on the website. Your continued use of services on the Platform will be taken as acceptance of the updated Privacy Policy.
6 Terms and Conditions of Platform
6.1 If you choose to avail services at our Platform, your transaction and any dispute over privacy is subject to this Privacy Policy and our Terms and Conditions of Platform, including limitations on damages, resolution of disputes, and application of the prevailing law in India. If you have any concern about privacy at the Website or Platform, please contact us with a thorough description, and we will try to resolve it. If you are found to be in non-compliance with laws and regulations, the Terms and Conditions published on the Platform, or this Privacy Policy, VenusBarter shall have the right to immediately block your access and usage of the Platform and VenusBarter shall have the right to remove any non-compliant content and/or information forthwith, uploaded by you and shall further have the right to take appropriate recourse to such remedies as would be available to it under various statutes.
7. Cookies
7.1 Our Platform uses cookies. A cookie is a small text file, which is stored on your computer, mobile phone, tablets etc. in order to recognize your computer at recurring visits. The cookie may transmit information via your browser with a purpose of authenticating or identifying the computer (via e.g. the IP address) or the user. Cookies may contain information such as registration data and user preferences. When a server receives a request from a computer which stores a cookie from the website, the server is able to use the information stored in the cookie in combination with the information stored on the server. To learn more about cookies, please visit the following site, which is not affiliated with VenusBarter: http://www.allaboutcookies.org/.
8 Your Rights
8.1 Your rights under applicable law may include access to the Personal Information we process about you, the right to have such Personal Information corrected, updated or erased, the right to restrict the processing of your Personal Information, as well as the right to data portability. Where we have obtained your consent for the processing of your Personal Information, you have the right to withdraw your consent at any time. This will not affect the lawfulness of the processing that has happened based on your consent prior to the withdrawal. To exercise these rights, you should make a written request using our contact details set out below and it may result in suspension or termination of our services being provided to you.
8.2 You also have the right to object, at any time, to the processing of your Personal Information which is based on VenusBarter’s legitimate interests. Further, if you wish to remove all your Personal Information from the Platform, you can do so by opting out of the Platform and uninstalling the Platform from your system(s).
9 Governing Statue
9.1 This Privacy Policy is governed by and is compliant with the applicable laws of India, in order to protect Personal Information of the end-user(s) of the services.
10 Grievance Officer
10.1 If you have any comments or inquiries about this Privacy Policy or if you would like to update information we have about you, or to exercise your rights, you may contact our Grievance Officer, Mr. Ram, write to him at Grievance@VenusBarter.in.