Data Privacy Policy

1. Definitions

1. The term “Data” shall be as defined under Paragraph 2
2. The term “Digital Lending Product” is a remote and automated lending solution that uses seamless digital technologies for customer acquisition, credit assessment, loan approval, disbursement, recovery, and related customer service.
3. The term "Personal Data" means any data about an individual who is identifiable by or in relation to such data.
4. The term “Process” shall mean in relation to personal data, means a wholly or partly automated operation or set of operations performed on digital personal data, and includes operations such as collection, recording, organisation, structuring, storage, adaptation, retrieval, use, alignment or combination, indexing, sharing, disclosure by transmission, dissemination or otherwise making available, restriction, erasure or destruction.
5. The term "Services" means any lending and non-lending service(s) that are provided by the Company to its customers and/or users.

2. Information We Collect

We along with our service providers collect various types of Data to provide you with our Services, while ensuring compliance with legal and regulatory requirements.

Data shall mean and include:

1. Personal Data
2. Contact Information: Name, age, gender, photo, address, phone number, e-mail id, your contacts, nominee details.
3. Identification and KYC Related Information: PAN, Aadhaar number / Virtual ID for the purposes of e-KYC authentication with the Unique Identification Authority of India (UIDAI), images, audios, videos and content recorded during such video call which shall be used for the purposes of credit appraisal.

*Note that submission of Aadhaar information is not mandatory and you may submit other Officially Valid Documents (e.g., Voter ID, Driving Licence, etc).

4. Transaction and Payment Information: Details of transactions contained in the SMS, and details about payments to and from you and other details of products and services.
   **Please note that we only collect details of transactions contained in SMSs. We do not collect, read, or store any personal SMSs. By consenting to provide us with the transactional SMS data, you release, acquit, and waive any and all claims against L&T Finance that arise from or relate to such SMS transactional data.
   **With regard to a Digital Lending Product, we shall not access mobile phone resources like file and media, contact list, call logs, telephony functions.
5. Usage and Technical Information: Your device details such as device identifier, internet bandwidth, browser type, operating system, mobile device model, browser plug-ins, and cookies or similar technologies that may identify your browser and plug-ins, and time spent, internet protocol (IP) address and location, login e-mail address and password. With regard to a Digital Lending Product, we shall not access location on a continuing basis.
6. Digital Interactions
7. Satellite Data
8. Application Data
9. Credit history information from credit bureaus, which shall be used to prevent and detect fraud and to offer certain credit or financial services to some customers.
10. Your demographic and photo information including but not limited to Aadhaar number, address, gender, and date of birth as a response received from UIDAI upon successful Aadhaar e-KYC.
11. Your information as obtained from email service providers, publicly available databases, joint marketing partners or other third parties as appropriate.
12. Any other additional information with your explicit consent.

3. Purpose and Use of Data

L&T Finance may Process your Data for the following purposes:

1. To create your account and verify your identity;
2. To fulfil your requests for products and services offered and subscribed and accepted by you;
3. To deliver to you any administrative notices, alerts, advice and communications relevant to your use of the Service;
4. For assessing the borrower's financial eligibility and to undertake credit assessment;
5. To share your Data with any third party in so far as required for purpose of providing additional Services and / or to similar Services to provide you with various value-added Services;

*List of third parties can be accessed on www.ltfinance.com as amended from time to time.

6. To share with credit bureaus (e.g., CIBIL, Experian, CRIF, Equifax) for credit scoring and reporting;
7. For market research, project planning, troubleshooting problems, technical support and fixing bugs;
8. To carry out credit checks or due diligence checks as lawfully required by us to detect and protect against error, fraud or other criminal activity;
9. To verify your identity and address details and to find branches nearest to you;
10. To enable secure downloads and uploads of documents related to loan, “Know Your Customer” (KYC);
11. To conduct the KYC compliance process as a mandatory prerequisite as per the requirements of various regulatory bodies, including UIDAI under the Aadhaar Act and its Regulations;
12. To validate, Process and/or share your KYC information, nominee details with other intermediaries, Regulated Entities (REs) or AMCs or financial institutions or with any other service providers as may be required;
13. To manage phone calls and SMS/texts, to send reminders, etc.;
14. To analyse your financial position/credit risk assessment;
15. For ongoing monitoring of my creditworthiness, assessment of repayment behaviour including collection efforts and identifying financial behavioural indicators during the tenure of the loan;
16. For KYC requirements like verification or authentication (any nature);
17. For the purposes of data enrichment, to make personalized offers of products and services, credit rating, promotion or marketing of Company’s product or its group companies or third party;
18. To provide information regarding insurance products, third-party products services, and related assistance;
19. For taking policy actions and segment/portfolio level decisions; and
20. To undertake activities as may be permitted under law/regulations/directions/guidelines or by any authority or under any license or registration of the Company.

The Data so collected shall be used only for the Purpose, or for such other purposes expressly consented by you.

4. App Permissions

If the User accesses the Planet App available on Google Play Store and/or App Store, on their mobile phones, L&T Finance may require certain device permissions to provide the User certain functionalities within the Planet App application in accordance with prevailing laws and regulations.

Planet App collects, Processes and retains the device permissions mentioned below:

Note: Access to permission can be managed by the user directly via device settings.

5. Handling Data with Consent

By using the Platform and/or our Services and/or by providing your Data, you consent to our use of your Data in accordance with this Privacy Policy, as may be amended from time to time. When you disclose any Data with respect to other people to us, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy. You also agree and consent to us collecting, storing, Processing, transferring, and sharing your Data with third parties or service providers for the purposes set out in this Privacy Policy. Further, if you have availed our Services, you agree and authorize L&T Finance to communicate with you via channels like phone calls and e-mails for the purposes set out in this Policy.

6. Use of Cookies

Cookies are small text files placed on your device to recognise repeat users, secure sessions, remember preferences, analyse usage, improve performance, and, where permitted, deliver personalised or advertising content.

Types of cookies: We use essential cookies (for core functions), performance and analytics cookies (to understand visitor behaviour), functionality cookies (to remember settings), and targeting cookies (for advertising and campaign measurement).

Data collected: May include device and browser details, IP address (or parts of it), pages visited, time spent, navigation paths, clicks and interactions, and referral or exit sources.

Third-party cookies: Some cookies are placed by third-party providers (such as analytics or advertising platforms) whose data use is governed by their own privacy policies.

Retention: Cookies may be session-based (expire when you close your browser) or persistent (remain for a set period depending on their purpose).

Your choices: You may manage or disable cookies via browser settings or our cookie-preference tools; however, certain site features may not function properly if cookies are restricted.

7. Sharing Your Information

Your Data is shared as per applicable laws, and in line with the purposes set out in this Privacy Policy. We treat your Data as private and confidential and we do not check, edit, or reveal it to any third parties except as provided under this Policy or where it is expressly agreed and where it is believed in good faith, such actions are necessary to comply with the applicable legal and regulatory processes or to enforce the terms of service. Data of the users will not be sold or otherwise transferred to unaffiliated third parties unless otherwise stated at the time of collection or without the approval of the user as the case may be. However, we might share, exchange and disclose information to our affiliates and / or group companies, agents and/or to any third party service providers and/or regulatory bodies and governmental authorities to deliver you products/services in the manner agreed by you.

Data will be shared, as applicable, on need-to-know basis, for the purposes and including but not limited to for the following purposes:

1. for enabling the provision of the products/services availed by you and facilitating the services between you and the service provider;
2. for enabling your borrowing journey by sharing information with authorized financial institutions and credit bureaus and reporting agencies to assess your creditworthiness and to report on your credit status and loan repayment behaviour;
3. to process loan disbursements and repayments;
4. for the Aadhaar authentication process by submitting Aadhaar information to Central Identities Data Repository (CIDR) and National Securities Depository Limited (NSDL);
5. for complying with applicable laws as well as meeting the Know Your Customer (KYC) requirements as mandated by various regulatory bodies, whose regulated service/product you opt through our services/Platforms;
6. for our business operations, including enabling your KYC process, eligibility checks, collection services, and storage of such information, as required by our lending partners;
7. if it is required by financial institutions to verify, mitigate, or prevent fraud or to manage risk or recover funds in accordance with applicable laws/regulations;
8. for offering additional financial products and services and for services related to communication, marketing, data and information storage, transmission, security, data analytics, fraud detection, risk assessment and market research;
9. enforce our product/service terms or Privacy Policy;
10. if required to do so by law or in good faith we believe that such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal process;
11. if requested by government authorities for government initiatives and benefits;
12. for grievance redressal and resolution of disputes; and/or
13. in the event of a merger, acquisition, re-organization, amalgamation, restructuring or sale of all or a portion of our assets with the acquiring entity or other relevant parties.

Lending Service Providers (as defined under applicable law) or third parties are also bound by a contractual obligation to ensure confidentiality of shared data and to comply with various technology standards/ requirements on cybersecurity stipulated by RBI and other authorities, as may be specified from time to time. Details of Lending Service Providers (where and as applicable) that are allowed to collect Data through the Platforms are as available on www.ltfinance.com.

While the information is shared with third parties as per purposes set out in this Privacy Policy, processing of your Data is governed by the policies of the third parties. We shall ensure stricter or no less stringent privacy protection obligations are cast on these third-parties, wherever applicable and to the extent possible. However, we do not accept any responsibility or liability for usage of your Data by these third parties or their policies.

It is clarified that any information that is freely available or accessible in public domain or any other law for the time being in force shall not be regarded as Data for the purposes of this Privacy Policy.

8. Storage and Retention of Data

We shall store the Data only in servers located within India. We shall retain your Data as may be required to carry out our operations under applicable laws / regulations / licenses or under the consent provided by you and only for a period that it is required for the purpose for which it was collected. However, even upon revocation of consent, all such Data collected shall be retained so long as you have availed Services from us or have an account with us and remain active to avail various services and/or such extended time period as may be required under the law or by any authority. In cases where you have not availed any loan or facility from us, we shall continue to store your Data until such time as the consent provided by you is withdrawn. In case of deactivation / termination of the account / Services with us, the Data provided will no longer be used unless consented for. We may retain Data related to you if we believe it may be required to prevent fraud or future abuse or if required by law such as in the event of the pendency of any legal/regulatory proceeding or receipt of any legal and/or regulatory direction to that effect or for other legitimate purposes.

We shall delete/destruct the Data in accordance with applicable laws, once it has completed its retention period.

9. Security of Data

We are ISO/IEC 27001:2022 certified and deal mostly with Data of users, and therefore, it becomes imperative to protect such information as soon as they are in our network. The ownership of the Data lies with our skilled IT Function Team. Below are the security measures taken to prevent misuse of this type of information.

1. We have implemented physical, administrative and technical security measures across the organization which are designed to prevent data loss, unauthorized access to Data and misuse, disclosure, alteration, damage or destruction of Data.
2. Data is encrypted at rest using strong encryption algorithms. The keys used for such encryption algorithms are stored securely and access to keys are restricted to authorized entities only.
3. We fully understand that the Data collected from individuals is under our guardianship. Therefore, we train our employees on the Privacy Policy as well as information security procedures regarding the appropriate access, use, and disclosure of Data.
4. We also conduct periodic risk assessments on the processes and information systems and audits of material third-party vendors dealing with Data of the customer/user.
5. We also conduct third party audit and assessment on periodic intervals for material vendors.
6. We have in place an incident response plan with trained personnel to respond to, investigate and mitigate the impact of any incident.
7. We maintain adequate plans for business continuity management, as well as disaster recovery processes for testing databases, servers, information systems and processes that handle Data.

You hereby acknowledge that L&T Finance is not responsible for any intercepted information sent via the internet, and you hereby release us from any and all claims arising out of or related to the use of intercepted information in any unauthorized manner.

This Privacy Policy shall be read in conjunction with Company Information Security and Information technology policies and procedures, as may be existing and applicable.

10. Third-Party Websites, Products or Services

Your use of our Platform to access the products and services of our service providers may result in the collection of Data by such third party service providers, which is subject to their privacy policies. To find out how these third party service providers will handle your Data, you can review their terms of service and privacy policy.

When you visit our Platform, our services may contain links to other websites or applications. We have no control over the privacy policies that apply to these websites or applications. The use of any Data you provide on these websites or applications is governed by the privacy policy of the operator of the application or website you are visiting once you leave our servers (you can determine where you are by looking up the URL in the location bar on your browser or on the page you are redirected to). Before using any applications or websites, you are requested to read through their policies or obtain access to them from the domain owner, since their policies may differ from ours. We disclaim all obligation and accountability with respect to how these third parties use your Data or their policies.

11. Access and Rectification of Personal Data / Revocation of Consent

You can access and review your Personal Data shared with us by placing a request with us and as a registered L&T Finance User, you can modify some of your Personal Data. In addition, you may at any time revoke consent given to us to store your Data by writing to [email protected]. Upon such revocation, you may lose access to services that were availed on the basis of the consent provided. In some cases, we may continue to retain your information as per the 'Storage and Retention' section of this Privacy Policy. To raise any of the above requests, you may write to us using the contact information provided under the 'Contact Us' section of this Policy. In case you have availed any Services from us, more particularly availed a loan from us, we shall continue to store, process and use the Data provided by you to us as per this Policy until the termination of the loan and/or additional period as prescribed under applicable law.

In case you wish to delete your account or Data, you may write to [email protected]. However, retention of your Data will be subject to applicable laws and our Privacy Policy.

For the above requests, L&T Finance may need to authenticate by requesting specific information from you to confirm your identity. This is a security measure to ensure that Data is not disclosed to any person who does not have a right to receive it or is not incorrectly modified or deleted.

12. Minor's Privacy

We do not knowingly solicit or collect Data from children under the age of 18 and use of our Platform is available only to persons who can form a legally binding contract under the Indian Contract Act, 1872.

13. Modifications to the Privacy Policy

L&T Finance reserves the right to modify this Privacy Policy at its discretion from time to time. Any amendments shall take effect immediately upon posting the revised Privacy Policy. We advise you to periodically review this page for the most recent information on our privacy practices. Your continued usage of our Services/Platform shall be deemed to be consent to the Privacy Policy as modified from time to time.

14. Applicable Law

Your use of our Platform will be governed by and construed in accordance with the laws of India. You agree that any legal action or proceedings arising out of your use may be brought exclusively in the competent courts/ tribunals having jurisdiction in Mumbai, India and irrevocably submit themselves to the jurisdiction of courts/ tribunals in Mumbai, India.

15. Protecting Personal data of Aadhar Number Holders:

Subject to obtaining the AUA/KUA license from UIDAI (“the License”), we will be permitted to directly use the online database of Aadhar to verify the identity of our customers/borrowers including the photograph seamlessly for the purpose of carrying out the KYC of our customers/borrowers before onboarding. The provisions governing privacy and protection of personal date of the Aadhar Number Holders (Aadhar Holders Personal Data) is detailed under Annexure A of this Policy. It may be noted that if any provision(s) of the Policy and Annexure A mean, read or interpreted differently, the provisions of Annexure A shall prevail for the purposes of governing the personal data of Aadhar Number Holders.

The Annexure A shall stand effective from the date of receipt of the License.

16. Complaints and Grievance Redressal

If you contact us to provide feedback, register a complaint, or ask a question, we will record any Data and other content that you provide in your communication so that we can effectively respond to your communication. Any complaints or concerns in relation to your Data or content of our Platform or any dispute or breach of confidentiality or any proprietary rights of user during use of the Platform or any intellectual property of any user should be immediately informed to the Grievance cum Nodal Officer, the contact details of whom are specified below:

Grievance officer

Mr. Vinod Varadan,

Grievance Redressal Officer

L&T Finance Limited (formerly known as L&T Finance Holdings Limited),

7th Floor, "Brindavan Building", Plot No 177,

C.S.T Road, Kalina, Santacruz (East),

Mumbai - 400 098

Phone: 1800 1020 476

Email: [email protected]