Privacy & Policy

The purpose of this Privacy Policy is to explain how we may collect, retain, process, share, and transfer your Personal Data when you use our Services. This Privacy Policy applies to your Personal Data when you use our Services and does not apply to online websites or services that we do not own or control, including websites or services that do not belong to us, in any case.

Introduction

This Privacy Policy explains what personal information we collect, with whom we share, and how you (the user of the Service) can prevent us from sharing certain information with certain parties. You should read this Privacy Policy carefully in its entirety. By downloading the app, you consent to the following.

Sarmaya Microfinance (Private) Ltd (“us”, “we”, or “Company”) is the exclusive licensee in Pakistan Territory of the internet resource www.sarmayamf.com. Sarmaya Microfinance (Private) Ltd, a company incorporated and existing and based under the Laws of Pakistan, is licensed and regulated as a Non-Banking Financial Company.

The application and software whether run through the internet resource sarmayamf.com or through the mobile application or on any other media platform shall hereinafter be referred to as the “App/Application”.

The mobile application for the Company, is perpetual and exclusive use for Pakistan and is owned and belongs to the Company. All loans that are dispersed through the application are underwritten by Company.

 

 

Persons using the App and  the services are hereinafter referred to as “Users”, “you” or “the Customer”. By accessing the App, you are accepting the terms of this Privacy Policy; and

By downloading the App, the “user” (hereinafter referred to as “you” or “your”), hereby gives consent to the collection and processing of your personal information for legitimate business purposes, including but not limited to determining your credit score(s), approving and providing a loan and your further, certification, consent and undertaking are as under:

“I (the “user”) hereby certify that all the information provided by me is true and correct to the best of my knowledge and that any misrepresentations or falsity therein will be considered as an act to defraud the Company, the App, and its partners. I hereby authorize the Company and the App to verify and investigate the above statement(s)/information as may be required, from the references provided by me and other reasonable sources. I further agree that this application and all supporting documents and any other information obtained relating to this application shall be used by and communicated to Company, and shall remain its property whether or not my credit score is determined, or the loan is approved or granted. I expressly and unconditionally authorize the App to disclose to any bank, its affiliate, and other financial institution any information regarding me. In particular, I hereby acknowledge and authorize:

  1. The regular submissions and disclosure of my basic credit data as well as any updates or corrections thereof; and

 

  1. The sharing of my basic credit data with financial institutions, duly licensed lenders, credit information bureaus, government offices or agencies authorized by law, and duly accredited credit reporting ”

 

We (the “Company”) value online privacy and security while browsing through the App and availing of the Services available on the App. We make every effort to ensure that the information you provide will not be misused. This privacy policy (“Privacy Policy”) would apply to information we collect when you register with the App, when you access or use the App, or avail the Loan and facilities on the App (collectively the “Services”).

 

Our goal in this Privacy Policy is to be completely transparent about the data we collect, and why we collect, use, share, store, and protect personal information about Users. Any capitalized term used but not defined in this Privacy Policy shall have the same meaning attributed to it in our User Terms and Conditions. We encourage you to familiarize yourself with our policies and let us know if you have any further questions.

 

 The Company is responsible to the extent of contents provided for the Loan and other facilities provided through the App. You acknowledge that Company would only be responsible for the contents displayed on the App, loan, and other facilities offered. The Company reserves the right in its sole discretion to remove any content or data, information, or material (“User Content”) from the App from time to time to secure the privacy of the Customer.

The foregoing limitations shall apply notwithstanding any failure of the essential purpose of any limited remedy and to the fullest extent permitted under applicable law.

App Permissions:

For the purpose of Credit Risk Assessment, we need the following Permissions from you, which you hereby consent to allow as under:

Phone Permission: Collect and monitor specific information about your device including your hardware model, operating system and version, unique device identifiers like IMEI and Serial Number, user profile information, and mobile network information to uniquely identify the devices and to ensure that unauthorized devices are not able to act on your behalf to prevent frauds.

Location Permission: Collect and monitor information about the location of your device to do a risk assessment for credit scoring.

Information Collected:

To create an account on App, you must provide us with the basic details and information required as part of our Customer Identification Process and you agree to our User Terms and Conditions and this Privacy Policy, which governs how we treat your information. The App collects basic information required to provide customized services (for example loan offers, content, and more relevant ads), including your name, mailing address, postal code, job title, reference person’s details, employer details, phone number, employment information, salary slips, declarations, your description and details  of your account, financial information such as bank account, etc.

You will register with us using your Facebook or LinkedIn, email and Gmail account or Google identity (“Third party sites”). You understand that, by creating an account or by registering through Third party sites, we and others will be able to identify you by your App profile. However, we will not be liable under any circumstance for the generation of your profile or the information you provide therein. We will ask for your bank account details only for the Service as required.

All the information that you shall provide to the APP is voluntary, including any sensitive personal information. You understand that App may use certain information of yours, which has been designated as ‘sensitive personal data or information’ under the law for the purpose of providing you the services and for sharing the information only with affiliates who are subject to this Privacy Policy..

The protection of your privacy and your data security is a top priority at the Company. There are security group and firewall checks to control the APIs with multi-level authentication, authorization, and verifications.

Please note that we always ask for your permission before accessing the information on your phone. We collect and monitor only your bank-related financial transaction SMS, names of transacting parties, transaction description, and amount to perform a credit risk assessment.

Data / Cookies

We may set cookies to track your use of the App. These are used to enhance your experience with our App. We use cookies to help us identify who you are, so your login experience is smooth each time. Cookies also allow us to collect Non-Personally Identifiable Information from you, like which pages you visited and what links you clicked on. The use of this information helps us to create a more user-friendly experience for all visitors. In addition, we may use Third Party Advertising Companies to display advertisements on our App. By using the app, you signify your consent to our use of cookies. Please note that if you decline or delete these cookies, some parts of the App may not work properly.

Cookies are small data files that a website stores on Your computer. We will use cookies on our website like other lending websites/apps and online marketplace websites/apps. Use of this information helps Us identify You in order to make our website more user-friendly. Most browsers will permit You to decline cookies but if You choose to do this it might affect service on some parts of Our Website.

Collection of Mobile Number and Email Address

In order to uniquely identify you, we collect your mobile number and email address when you sign in. This helps us ensure that no unauthorized device or person is acting on your behalf.

Collection of Location

We collect location information from your device to reduce the risk associated with your account.

Collection of Reference Contacts

As a part of our loan verification process, we require references from the loan applicant. In this regard, during filing the form on the  App, we collect reference contacts from you refer by yourself so that in case of your non-availability as the loan applicant those references can be contacted. These contacts are willingly given by you when you apply for the loan.

Camera

We require the camera information permission to provide you with an easy/smooth experience and to enable you to click photos of your KYC documents along with other requisite documents and upload the same on the App during your loan application verification process.

The App has only one-time access to your camera and to the picture/photo/selfie  you upload on the APP while applying for the loan for the purpose of KYC.

Collection of Other Non-Personal Information

We automatically track certain information about you based on your behavior on our Platform. We use this information to do internal research on our users’ demographics, interests, and behavior to understand better, protect and serve our users and improve our services. This information is compiled and analyzed on an aggregated basis. We also collect your Internet Protocol (IP) address and the URL used by you to connect your computer to the Internet, etc. This information may include the URL you just came from (whether this URL is on our website or not), which URL you next go to (whether this URL is on our website or not), your computer browser information, and your IP address.

We retain this information as necessary to resolve disputes, provide customer support, and troubleshoot problems as permitted by law.

If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Website, we collect such information into a file specific to you.

Security Information

You can access your personal identity details on our App through your login and password. We recommend that you do not share your password with anyone. In addition, your personal details are stored on a secure server that only selected personnel contractors and authorized Agencies have access to. We encrypt certain sensitive information using Secure Socket Layer (SSL) technology to ensure that your personal details are safe as it is transmitted to us.

The digital lender shall bear exclusive liability for all occurrences of digital fraud arising due to security vulnerabilities, operational shortcomings, deficiencies in the application’s architectural design, or any other malfunctions within the application. This responsibility includes the obligation to investigate, address, and remediate any such instances promptly, as well as compensating affected parties as required by applicable laws and regulations. Furthermore, the digital lender is committed to implementing robust security measures, conducting regular audits, and continuously improving the application’s infrastructure to mitigate the risk of digital fraud and uphold the trust of its users.

Privacy Policies of Third-Party Websites

This Privacy Policy only addresses the use and disclosure of information we collect from you. Other websites/apps that may be accessible through this App have their own privacy policies and data collection, use, and disclosure practices. If you link to any such website, we urge you to review such website′s privacy policy. We are not responsible for the policies or practices of third parties.

We may share all information we collect from you, including personal information with any third party if we in good faith believe it is required for the purposes of our compliance with any applicable law, regulation, legal process, or enforceable governmental request/ action or any manner required for the purposes of protecting our rights or interests. These third-party websites and advertisers or internet advertising companies working on our behalf, sometimes use technology to send or serve data that appear on the App. They automatically receive your IP address when that happens. They may also use cookies, JavaScript, web beacons, and other technologies to measure the effectiveness of their advertisements and to personalize advertising content. Please be advised that we do not have access to or control over cookies or other features that they may use, and the information practices of these advertisers and third-party websites are not covered by this Privacy Policy. Therefore, we are not responsible for the information or content they may contain, nor are we responsible for the privacy practices employed therein. Please contact them directly for more information about their privacy policies. This Privacy Policy applies solely to information collected by us through the App.

Any personal information will be used but not limited to allowing you to log in to your account or to resolve specific service issues, inform you of our new services or features, call center verification, or to communicate with you in relation to your use of the App. Any other information we collect will be used for:

 

  • Our business purposes and this may include the viewing or advertising of services or relating to any associated services;
  • Analytical purposes, data usage;
  • Improving the Application, or your user experience; and
  • Providing targeted advertisements to you.

We share your personal information internally with those staff members who need it to carry out your instructions regarding the receipt of marketing information, Loan Processing, and recovery of Loan. We will not disclose your personal information to any third party unless required to do so by law and/or covered under this Privacy Policy.

For those Users who have registered for the mailing list, their personal information is kept until we are notified that they no longer want their information stored.

Persons who supply us with their telephone numbers may receive communication from us via telephone, text message, or emails, pertaining exclusively to new services or any upcoming events. If you do not wish to be on our mailing list, you can let us know of your updated preferences by either emailing us at support@sarmayamf.com or choosing the “unsubscribe” option.

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Our App complies fully with all the applicable and relevant laws of Pakistan.

Disclosures

We respect that you do not want your personal information to be shared with other companies at any time. However, we may require you to share your Personal Information with our affiliates, business, and non-business partners including but not limited to credit information companies, and credit information bureaus , where we feel that you will be assisted better for the purpose of underwriting and approval of your loan or any other financial product transaction/related transaction. We share information as described below in accordance with this Privacy Policy. We will keep your personal information confidential and limit access to it to those who specifically need it to conduct their business activities, except as otherwise permitted by applicable law.

 

Business Transfers: As we continue to develop our business, we might sell or buy business units. In such transactions, customer information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy (unless, of course, the customer consents otherwise). Also, in the unlikely event that Loans, assets, or substantially all of its assets are acquired, customer information will of course be one of the transferred assets.

Protection of App: We release personal information when we believe release is appropriate to comply with the law; enforce or apply our User Terms and Conditions and other agreements; or protect the rights, property, or safety of the App, our users, or others. This includes exchanging information with other companies, organizations, governments, or regulatory authorities for fraud protection and credit risk reduction.

 To the Government and other judicial bodies as required under the law in order to comply with the legal obligations (without the prior permission of customers).

 App shall also contain links to the other websites. Customers are requested to go through the respective privacy policies disclosed under the relevant sites to familiarize themselves.

 

Policy Changes:

We may update this Privacy Policy to reflect changes to our information practices to facilitate the borrowers/customers. You are encouraged to check this privacy policy on a regular basis to be aware of the changes made to it to secure your privacy.

General Matters

The Accuracy and Confidentiality of your personal data and Account Information is your Responsibility. You are responsible for maintaining the secrecy and accuracy of your password, email address, and other account information at all times. We recommend a strong password that you do not use with other services. We are not responsible for personal data transmitted to a third party as a result of an incorrect email address. You hereby indemnify the Company, its directors, officers, and affiliated parties against any loss or damage [and any consequential legal action, criminal or civil against the Company], caused to you by the breach of your responsibility undertaken under this clause and the responsibility you assume to maintain the secrecy and accuracy of your account, log in and passwords.   

 

Confidentiality and Security: We use commercially reasonable security measures to protect against the loss, misuse, and alteration of the information under our control. However, we cannot absolutely guarantee the protection of any information shared with us by any negligence in maintaining the security of your login and password by you.

We make all User information accessible to our employees, agents or partners, and third parties only on a need-to-know basis, and bind all such employees, agents or partners, and third parties to strict confidentiality obligations. Notwithstanding the above, we are not responsible for the confidentiality, security or distribution of your personal information by our partners and third parties outside the scope of our agreement with such partners and third parties. Further, we shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond the reasonable control of the App including, including acts of government, computer hacking, unauthorized access to computer data and storage devices, computer crashes, breach of security and encryption, poor quality of Internet service or telephone service of the User, etc.

 

Contact Us:

If you have any questions or suggestions or wish to make a complaint you can contact us at support@sarmayamf.com or write to us at the following address:

Office 1010, 10th Floor ISE Tower

Customer service number: +92 300 0341228/ +92 300 0341229

The Applicable laws of the jurisdiction may also provide you with specific privacy protections. We will comply with such applicable laws with respect to our use of your information.

 

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