CrediFiable

CREDIFIABLE PRIVACY POLICY


Last Updated: 8 September 2016

OneFiable Technologies Private Limited, also known as (“CrediFiable”), has is compliant under the Information Technology Act 2008 (“Act”) and the rules thereof, more specifically the Information Technology Intermediaries Guidelines Rules 2011 (“Rules”), signifying that this privacy statement and our practices have been reviewed for compliance with the Act and Rules and applicable laws. This privacy policy (“Policy”) covers the information collected through this Web site, https://www.credifiable.com. If you have questions or concerns regarding this Policy, you should first contact info@credifiable.com.

This Policy applies to https://www.credifiable.com owned and operated by CrediFiable. Your privacy and the protection of your personal and sensitive information are important to us. We collect and/or store certain types of information from and about you, it is necessary to explain our policy and the terms and conditions surrounding the capture and use of that information.

This Policy discloses which information we collect and how we use it, as well as the choices you can make about the way your information is collected and used. We also explain how any sensitive and/or personal information that we may request will be used; these explanations can usually be found on the same pages where the information is requested. We also detail below our security policy which describes how your personal and sensitive information is protected both electronically and physically.

In general, and as described in detail below, we collect several types of information from you, such as:

  • Personal information required to verify your identity;
  • Personal and financial information necessary to assess your eligibility to borrow or lend money through CrediFiable;
  • Social media particulars required for the assessment of your credit score.
  • Optional personal information (such as details about your loan) you may wish to share in the furtherance of your goals in using our web site;
  • Information about your visits to and use of this web site to help us maintain the appropriate features, functionality and user experience.;

CrediFiable works with a number of trusted partners that perform vital functions as part of our operations, including E-sign providers, credit bureaus, collection agencies, and electronic payment service providers. In addition, since all loans originated through CrediFiable are made to borrowers by third party lenders, if you request a loan, your information will be shared with the third party lender who has lent you the loan. Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or to perform other specific services, like collections. Our partners are legally required to keep your information private and secure.

You accept this Policy when you sign up for or use our products, services or any other features, technologies or functionalities offered by us on our website or through any other means (collectively the “CrediFiable Services“).

INFORMATION WE COLLECT FROM YOU AND ABOUT YOU

We collect personal and financial information from you while you use the web site, and most of this collection occurs during registration. Some information is required and some is optional, some will remain private and some will be displayed to other users. We always let you know which is which. Additional information may be gathered during your subsequent use of the site, whenever you choose to provide it.

Certain personal information must be supplied during the member, investor and borrower registration processes, as indicated below, in order to (a) enable registered users to login to the site, (b) determine borrowers' eligibility for loans through our proprietary credit scoring process, (c) verify borrowers' and investors' identities, (d) establish borrowers' and investors' ability to make and request loans and (e) guard against potential fraud. This basic personal information includes:

  • Your name (member registration);
  • Your E-mail address (member registration);
  • Your date of birth (borrower/investor registration);
  • Your home address and telephone number (borrower/investor registration);
  • Your Permanent Account Number (borrower/investor registration);
  • Your Bank Account Information-such as account and routing number (borrower/investor) ;

When you register as a borrower, we will use this information to pull a credit report from a credit bureau to determine your creditworthiness as well as to help investors assess your loan request in the context of your overall financial situation. We will also use your required and optional information to facilitate activities and transactions that need to occur during online person-to-person lending, such as:

  • Generating borrower profiles on the web site;
  • Assigning you a borrower credit grade based on your credit history, financial circumstances and social media particulars;
  • Enabling our financial services partners to implement automatic payments and fund transfers;
  • Contacting you if there is a problem completing a transaction you requested or to discuss a problem with your account;
  • Implementing collection activities as needed;
  • Maintaining regular communications with you concerning transactions you initiate, such as requesting information or assistance, submitting a loan request, making payments, transferring funds, etc.;
  • Allowing you to add new bank account information and save to your online profile.

When you register as an investor, we will request some required and optional data in order to facilitate such activities as:

  • Generating an investor profile on the web site;
  • Enabling our financial services partners to implement fund transfers and the receipt of borrower payments;
  • Contacting you if there is a problem completing a transaction you requested or to discuss a problem with your account;
  • Maintaining regular communications with you as may be necessary to execute transactions you request, such as submitting loan portfolios and transferring funds, etc.

In addition, we gather names and E-mail addresses of people who contact us through our web site with questions about our company or lending/borrowing operations. We collect this information for the sole purpose of responding to such inquiries and do not store the contact information.

COMMUNICATIONS FROM OUR WEB SITE

When you register on our site you will receive e-mails that confirm specific actions you requested. You will receive notifications confirming your registration, the successful verification of e-mail addresses and bank accounts, and confirmation of successful submissions of loan requests and portfolios. You will also receive progress updates on the status of loan requests and submitted portfolios. These are transactional notifications that you cannot opt out of receiving, as they are in place to protect the security of your account and your personal information. We will also send you responses to any E-mails you send us. From time to time, we will also send user surveys and requests for user feedback regarding user experience and site operations. The completion of these surveys or requests for feedback is strictly voluntary. If you do not wish to receive these surveys or user feedback E-mails, you may opt out by writing to info@credifiable.com or by following the unsubscribe instructions located at the bottom of each E-mail communication.

CrediFiable will send you e-mail notifications from time to time, and these are required elements of your transactions on our web site, such as confirmations of particular actions you have taken. These required notices are sent typically to notify you of a change in status such as when you are confirmed as a borrower or investor, or for legal or security purposes. For example, certain notifications are sent for your own protection to ensure that no one can make a change to your account without your knowledge, such as confirming the addition of a new e-mail address or linked external bank account. These notifications are sent to you so that you can be assured that no one is making changes to your account without your knowledge. In other cases, these notifications involve changes to various legal agreements or site policies. Generally, you may not opt out of these service related e-mails.

When you register to our site, we will ask you for your employer’s name and phone number. CrediFiable stores this information for the sole purpose of verifying your employment.

Your employer may contact us at info@credifiable.com to request that we remove this information from our database.

HOW LONG WILL MY INFORMATION BE STORED?

We maintain electronic loan application information for funded/declined/withdrawn loans for a period of at least 5 years.

HOW AND WHEN YOUR INFORMATION IS SHARED WITH OTHER PARTIES

We do not sell, share, rent, or trade your personal information with third parties other than as disclosed herein.

Information is shared with other parties in the following ways:

  • Required information (such as name, address and e-mail address) and optional information about borrowers and investors is displayed on profiles that members can update at any time; certain information is optional (such as additional phone number) and you can choose not to supply it and/or can remove the optional information at any time.
  • Information (such as gross income, length of employment).
  • Financial and credit information about borrowers is displayed to qualified investors on loan listing pages.
  • Information is shared directly between users and other or potential users (who are only able to view loan postings but do not have access to the full loan listings). Information shared directly by users might contain personal information (such as name and E-mail address).
  • Information may be shared with collection agencies and/or service providers but only if they are contractually obligated to keep such information confidential.

For privacy purposes, borrowers and investors remain anonymous on the site and are identified only by their screen names. CrediFiable will assign a unique screen name to each member. This automatic screen name is composed with unique combination of numbers and letters. Borrowers will be able to see the screen names of their investors and vice versa. The loan listing pages include borrowers' credit grades and other financial information that is shown to qualified investors so that they can effectively evaluate loan requests. Loan listings also contain certain personal information (such as name and e-mail address) and, in some cases, answers to questions posed by investors that are incorporated into loan listings.

We may share your information with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your personal information when we believe that disclosure is reasonably necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our Web site.

CrediFiable works with a number of trusted partners that perform vital functions as part of our operations, including without limitation E-sign providers, credit bureaus, collection agencies, data and background verification agencies and electronic payment service providers with whom personal information is shared only to the extent necessary for us to process the transactions you initiate or perform other specific services with our partners legally mandated to keep your information private and secure.

These third parties are prohibited from using your personal information for promotional purposes but are authorized to use your personal information only as necessary to provide these services to us.

We may also disclose your personal information if CrediFiable is involved in a merger, acquisition, or sale of all or portion of its assets, you will be notified via E-mail and/or a prominent notice on our web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

WHERE YOU CAN FIND AND/OR CORRECT YOUR INFORMATION

You can access all of your personal information that we collect online and maintain by visiting your profile at www.credifiable.com. This section of the site is password-protected to better safeguard your information. As a registered user, you can correct, update, amend your password, E-mail address, physical address, phone number at any time on the website. Further, in the event that you need to modify your bank account information disclosed to CrediFiable or change any other information in your profile, you may do so by contacting us at info@credifiable.com. You may also ask to have your personal information deleted/removed from a public forum on our site and make changes to sensitive account information in order to protect your privacy and security by contacting us at info@credifiable.com. We will respond to your access request within 30 days.

We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at info@credifiable.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

WEB-RELATED INFORMATION COLLECTION

Technologies such as: cookies, beacons, tags and scripts are used by CrediFiable and our marketing, affiliates, or analytics partners. These technologies are used in analysing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

We use cookies for login authentication. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.

As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.

We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, and particularly to prevent you from identity theft.

We use Local Shared Objects, such as Flash cookies, AND/OR Local Storage, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSOs such as HTML 5 to collect and store information.

Various browsers may offer their own management tools for removing HTML5 LSOs. To manage Flash cookies, please click here.

We partner with a third party ad network to either display advertising on our web site or to manage our advertising on other sites. Our ad network partner uses cookies and web beacons to collect non-personally identifiable information about your activities on this and other Web sites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here. Please note this does not opt you out of being served advertising and that you will continue to receive generic ads.

Some of our pages utilize framing techniques to serve content to from our partners while preserving the look and feel of our site. Please be aware that you are providing your personal information to these third parties and not to www.credifiable.com.

Links to Other Sites

We may offer links to partners' sites. We make the decision to provide links to these sites based on the quality of information provided at the time the links are enabled, and we make every effort to monitor the continuing quality of content provided on these sites. However, these external sites are not subject to this privacy policy. Further, CrediFiable has no control over the content of these sites. The data collected and shared by such third-party websites is governed by their concerned privacy policy, which we do not exercise any control over. Accordingly, please consult the privacy policies on these sites before you provide them with any of your personal information.

CREDIFIABLE SECURITY POLICY

Industry-leading Standards and Controls

We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at info@credifiable.com.

CrediFiable takes strong steps to safeguard your personal information through vigorous physical, electronic and operational policies and practices. All data is considered highly confidential. Data can only be read or written through defined service access points, the use of which is password-protected. The physical security of the data is achieved through a combination of network firewalls (there is no direct communication allowed between the database server and the Internet) and servers with hardened operating systems, all housed in a secure facility. Access to the system, both physical and electronic, is controlled and sanctioned by a high-ranking manager.

Further, we also equip our servers with Secure Socket Layer (SSL) certificate technology to ensure that when you connect to our web site you are actually on our site. SSL also ensures that all sensitive (such as bank account information) and personal data entered into the web site is encrypted. To verify that SSL is being used, look for the key or padlock icon on your browser. For further encryption protection, we use a 128-bit secure browser for logins and transactions. Our site also makes use of "CAPTCHA" technology, which is a test that we use to ensure certain sensitive transactions are being initiated by a human and not by another computer. The test involves viewing a distorted image of a word that a computer would not be able to interpret and then entering in the text shown in the image. Finally, we subject our systems to periodic security audits to ensure that your information is thoroughly protected and secure.

Session Time-outs

We also employ session time-outs to protect your account. You will be logged out of the site automatically after a specified period of inactivity. This time-out feature reduces the risk of others being able to access your account if you leave your computer unattended.

Protection of Account Numbers

When we contact you about your account to confirm a funds transfer, we only reference the last four digits of your bank account number; this is done for your protection so that you will recognize the source or destination account as one which you own. Further, we employ strict access standards ensuring that only the senior-most employees or partner representatives have access to your account numbers and other sensitive information. This access is only granted in order to complete transactions which you request or to provide regular ongoing service to your account.

Passwords

At a minimum, we require the use of both numbers and letters in your password. We have also instituted secure steps by which you can regain access to your account should you forget your password, including the use of a security question. Your password is not known to any employee or third party with whom we may partner, and we will never ask for your password as a means of identifying yourself. You should never share your password with anyone, and if you ever receive an e-mail purporting to come from CrediFiable that asks for your password, you should immediately report this development.

WHAT YOU CAN DO

In addition to our own substantial efforts, you can take several precautions to protect the security of your computer and personal information. For instance, you can start by using a well-chosen password. You should avoid using any information that others can easily learn about you, such as a family member's name or birthday, and you can also use special characters in place of letters. We also recommend that you change your password frequently. You can also install and regularly update antivirus and firewall software to protect your computer from external attacks by malicious users. When you are finished with a session on our site, be sure that you log out and close the browser window.

To protect your account, we send automatic notifications confirming certain actions taken on your account, such as changes to a password or external linked account. We do this for your own protection so that you can be sure no one else is making changes to your account without your knowledge. However, the security offered through these notifications can be undermined if other people have access to your E-mail account. Therefore, you might consider restricting access to the E-mail account you registered with on this site and/or changing your password on that E-mail account frequently.

If you use a computer that is accessed by other people, such as in a public library or Internet cafe, we recommend that you take special precautions to protect the security of your account and personal data. When you are finished using our site, you should log out completely, then close the browser window and clear the browser's cache files.

You should also be aware of fraudulent attempts to gain access to your account information known as "phishing." Phishing is a tactic used by scammers in which unsuspecting people are brought to a web site by a genuine-looking E-mail purporting to be from a legitimate company. The phony or "spoof" E-mail takes the person to a web site that looks legitimate but in fact is not. Either in the E-mail itself or on this fake site, scammers will ask for login information to gain access to people's accounts and withdraw their money. CrediFiable will never ask you for your login information in the context of any E-mail. In general, you can protect yourself against phishing by never providing personal or login information via an E-mail—instead, go the web site directly. You might also make it a habit to check the URL of a web site to be sure that it begins with the correct domain. In the case of CrediFiable, you should always ensure the URL begins with http://www.credifiable.com, https://www.credifiable.com.

WE MAY MAKE CHANGES TO THIS POLICY

We may update this privacy policy to reflect changes to our information practices. If we make material changes we will notify you by mail (sent to the e-mail address specified in your account) or by means of notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

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