A. Third Unicorn Private Limited, a company duly incorporated under the Companies Act, 2013, bearing CIN U72900DL2022PTC401319 and having its registered office at 489/55/4, Second Floor, KH. No. 489/55, Vill -- Sheikh Sarai, Malviya Nagar, Maharishi Dayanand Marg, Corner Market Malviya Nagar (South Delhi), New Delhi -- 110017, India ("Company" or "We" or "Our" or "Us")
The Company owns and operates the ‘Fund My Staff’ website (https://dev.fundmystaff.com// ) and the mobile application ("Fund My Staff") (Website and App are collectively referred to as "Platforms").
The Company through the Platforms shall offer from time to time various types of services for User to be able to get credit facilities and linked services ("Service(s)") to its users ("User(s)" or "You" or "Your").
The mobile application ("Fund My Staff") is owned, operated, and managed by Third Unicorn Private Limited, a Loan Service Provider ("LSP"). The App serves as a digital platform for facilitating loan applications and related services. All loans offered through the App are originated, sanctioned, and disbursed solely by Ash Grove Capital Private Limited (CIN: U65999DL2018PTC329168) ("Lender"), a duly authorized lending entity, in accordance with applicable laws and regulations. The Company does not itself provide or disburse loans and acts only as a technology platform enabling users to access lending services provided by The Lender. Any personal information collected through the App is stored in the servers owned by The Lender. All credit facilities accessed through the Platforms are originated, sanctioned, and disbursed by the Lender.
B. Please note that You are accepting the practices described in this Privacy Policy ("Privacy Policy") when You access and use the Services regardless of how You access or use them or engage with Us, including through mobile devices.
Your use of the Services is also subject to the Terms & Conditions. Please read this entire Privacy Policy to make sure You understand it, as by accessing the Services You agree to be bound by the terms and conditions of the Privacy Policy and consent to the collection, storage and use of information relating to You as provided herein.
By using the Services and accessing any of the Platforms, You expressly consent to Our use and disclosure of Your personal information in accordance with this Privacy Policy. You should also read the Terms & Conditions carefully, and make sure You understand and agree to them before using the Services/Platforms.
C. Our Privacy Policy explains what information We collect when You visit the Platform or use the Services, as well as ways We might store, use or share it. We are only describing Our own practices and this policy does not apply to third parties. We do not own or control, including other companies You might interact with on or through the Services and/or Platform.
D. This Privacy Policy covers both “online” (e.g., web and mobile services, including any websites and mobile applications operated by Us however accessed and/or used, whether via personal computers, mobile devices or otherwise) and “offline” (e.g., collection of data or registration of documents) activities.
This document is published as an electronic contract and shall be construed in accordance with the provisions of the Information Technology Act, 2000, Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules (SPDI Rules), 2011 (as applicable) and Digital Personal Data Protection (DPDP) Act, 2023 (as enforceable), and is subject to the relevant guidelines, directions, circulars, etc. issued by relevant government authorities, from time to time.
E. Our Privacy Policy is subject to change from time to time without notice and it is strongly recommended that You periodically review Our Privacy Policy as available on the Platforms. In case You need any clarifications regarding this Privacy Policy, please do not hesitate to contact Us at contact@third-unicorn.com
1. Your consent
By using Our Platform(s)/ Our Services and/ or by providing Your information, You consent to the collection, transmission, storage and use of the information (including Personal Information and Sensitive Personal Data as defined below) You disclose on the Platform(s) in accordance with this Privacy Policy, including but not limited to Your consent for collecting, using, sharing and disclosing Your information as per this Privacy Policy and applicable law. If We decide to change our Privacy Policy, the updated changes shall be available on the Platform(s), so that You are always aware of what information We collect, how We use it, and under what circumstances We disclose it.
You consent that all information is being provided by You voluntarily and with prior knowledge of the usage of the same in a way as specified herein this Privacy Policy. You specifically agree and consent to Us collecting, storing, processing and sharing information (including Personal Information) related to You with Our customers, third parties, service professionals or to registered business partner/users and in accordance with the terms as set out in this Privacy Policy and the DPDP Act 2023, as amended from time to time.
You shall have the right to withdraw consent at any time (to the extend processing is based on consent) by communication in writing addressed at contact@third-unicorn.com The withdrawal shall not affect the lawfulness of processing based on consent before its withdrawal.
2. Types of information We collect
2.1 We collect the following types of information from You when You register on the Platforms and use Our Services:
• (i) "Personal Information" means any information that relates to an individual, which, either directly or indirectly, in combination with other information is capable of identifying You.
• (ii) "Sensitive Personal Data" means Personal Information which consists of Your information relating to bank account or credit card or debit card or other payment instrument details and biometric information, any detail relating to the above clauses as provided by You to Us for providing Services; and any of the information received by Us from You for processing, stored or processed under lawful contract or otherwise.
• (iii) Non-personal information, which is information that does not exclusively identify You but is related to You nonetheless such as, information about Your interests and demographics.
2.2 We may automatically track certain information about You based upon Your usage of the Platforms. We use this information to do internal research on Our User's demographics, interests, and behaviour to better understand, protect and serve our Users. This information is compiled and analysed on an aggregated basis. This information may include the platform that You just came from, which platform You next go to, Your computer/ mobile browser information, Your Internet Protocol address, and other information associated with Your interaction with the Platforms. By using the Services, You are authorizing Us to gather, parse data and retain basic data which are related to the provision of the Services.
2.3 We may collect a set of numbers that serve as that computer's Internet Protocol or "IP" address. The IP address does not reveal any further information about You other than the IP address from which You have accessed the Platforms.
3. Personal Information
3.1 While providing You access to the Platforms/Services, We collect the following category of Personal Information: (i) information You give Us, (ii) automatic collection of certain information, and (iii) information from other sources including service providers, partners, and publicly available sources.
3.2 We, on the Platforms, also collect and store Personal Information (including Sensitive Personal Data) provided by You, including but not limited to the following:
(i) Information provided by You at the time of registration or vide electronic communication such as Your name, address, email ID, phone number, bank account details, financial information, unique identifiers, and preferences information including favourites and history;
(ii) Information provided by You to assess Your creditworthiness;
(iii) Information that You provide to Us over telephone or in physical form whether sent through post and/or courier and/or handed over to Our representatives in person. We may make and keep a record of such information shared by You;
To prevent unauthorized access and/or fraud on Your account on the Platforms, We collect and monitor specific information about Your device including its hardware model, operating system and versions and identifiers like IMEI number and serial number of Your primary device used for availing Services.
3.3 Notwithstanding anything contained herein or elsewhere, We shall not access mobile phone resources like file and media, contact list, call logs and telephony functions. We may collect and monitor only financial transactional SMS to help Us perform a credit risk assessment, however no personal SMS is accessed, stored and collected.
3.4 We may take a one-time access for camera, microphone, location or any other facility necessary for the purpose of on-boarding/KYC requirements.
3.5 We do not store or collect any biometric data, except to the extent permitted/allowed under extant statutory guidelines.
4. How We use personal information
4.1 We use Your Personal Information to operate, provide, and improve our Services including: providing, delivering, processing transactions related to Us; measure, support, and improve our Services; provide recommendations and personalization; comply with legal obligations; communicate with You; marketing; fraud and abuse prevention and credit risks; sending administrative notices, Service-related alerts and other similar communication with a view to optimizing the efficiency of the Platforms; to enforce Our Terms and Conditions; other purposes for which We may seek Your consent.
4.2 Personal information about Our User is an important part of Our business. We share personal information for the following purposes with the authorised vendors/ affiliates only:
1. Transactions involving third party payment intermediaries: By agreeing to this Privacy Policy and the Terms & Conditions, You give consent to Your financial information being shared with third party payment intermediaries, including transactional SMS (sent by 6-digit alphanumeric senders) about bank transactions, KYC, verification and remittance to Your bank account directly;
2. Third party service providers: We employ other companies and individuals to perform functions on Our behalf, for delivering hardware, sending communications, processing payments, assessing credit and compliance risks, analyzing data, providing marketing and sales assistance, conducting customer relationship management, and providing training. With Your prior consent, these third party service providers shall have access to personal information needed to perform their functions, but may not use it for other purposes.
3. Business transfers: As We continue to develop Our business, We might sell or buy businesses or services. In such transactions, personal information generally is 1 (one) of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy (unless, of course, the individual consents otherwise). Also, in the unlikely event that the Company or substantially all of its assets are acquired, Your information will of course be one of the transferred assets.
4. We may process, use or disclose your Personal Data where required or permitted under applicable law, including to comply with legal obligations, court orders, regulatory directions, governmental requests, or any duly authorised legal process, or to enforce our terms and protect the rights, interests, property or security of the Company, our users or others.
5. We may also process Personal Data for facilitating subsidies, benefits, licences, permits, certificates or other government-related services, as well as in situations involving medical emergencies, public health events, disasters, security incidents or protection of life, health and safety, in accordance with applicable legal and data protection requirements.
6. At Your option: Other than as set out above, We shall seek Your consent when personal information about You might be shared with third parties, and You will have an opportunity to choose not to share the information.
7. You hereby unconditionally agree and permit that Company may transfer, share, disclose or part with all or any of Your Personal Information, within and outside of the Republic of India to Company and to third party Service providers/ partners/ banks and financial institutions for one or more of the purposes listed above or as may be required by applicable law. In such cases, We will attempt to contractually oblige the receiving third parties of the Information to ensure the same level of data protection that is adhered to as by the Company under applicable law and also ensure that prior consent has been obtained by such third party.
8. You further agree that such disclosure, sharing, and transfer of Your Personal Information and Non-Personal Information shall not cause any wrongful loss to You or to any third party, or any wrongful gain to us or to any third party.
5. Location of personal information
The Company is located in India, and the information is stored in servers located in India. Whenever We transfer personal information to other jurisdictions, We will ensure that the information is transferred in accordance with this Privacy Policy and as permitted by applicable laws including applicable data protection laws.
6. How We secure information
Your Security is Our highest priority and We design Our systems and protocols with Your security and privacy in mind, and in furtherance of the same We ensure the following:
6.1 We maintain a wide variety of compliance programs that validate our security controls.
6.2 We protect the security of Your information during transmission to or from the Platforms/Services by using encryption protocols and software.
6.3 We maintain physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of personal information. Our security procedures mean that We may request proof of identity before We disclose personal information to You.
We use appropriate technical, organizational, and administrative security measures to protect any Personal Data We process and store from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We have put various safeguards in place including strong firewalls, encryption, access control, restricted database and retention policies to guard against unauthorized access and unnecessary retention of Personal Data in Our systems.
However, no company or service, including Company can guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of your Personal Data at any time.
We follow generally accepted industry standards to protect the Personal Information submitted to Us, both during transmission and once We receive it. We host the API in a secure server environment that uses advanced technology to prevent interference or access from outside intruders. Our security practices and procedures limit access to personal information on a need-only basis.
7. Third Parties
Our Services/use of Platforms may include third party links to other websites and/or applications. Such websites are governed by their respective privacy policies, which are beyond Our control. Third party advertising partners may collect information about You when You interact with their content, advertising, or services. ‘FundMyStaff’ is not responsible for the privacy practices or the content of such websites.
8. Access and choice
You can view, update, and delete certain information about You, Your account and Your interactions with our Services/Platforms. If You cannot access or update or delete Your information Yourself, You can always contact Us for assistance.
You have choices about the collection and use of Your personal information. Our Services/Platform include settings that provide You with options as to how Your information is being used wherein You can choose not to provide certain information.
You may request Us to delete Your information by submitting a request for account deletion through the Platform. On submitting a request to delete Your account, You confirm/understand that: (i) You have no outstanding credit facilities availed on the Platform or any amounts due to any third parties on account of any credit facilities availed on the Platform ; (ii) You have no unresolved grievances in relation to the any of the Services provided by Us or any previous dealings with Us; (iii) Your account will be permanently deleted, and it will not be possible to reactivate Your account; and (iv) approved credit limits will be deactivated.
9. Retention of information
Your personal information may be retained and may continue to be used until: (i) the relevant purposes for the use of Your information described in this Privacy Policy and/or Terms and Conditions are no longer applicable; and (ii) We are no longer required by applicable law, regulations, contractual obligations or legitimate business purposes to retain Your personal information and the retention of Your personal information is not required for the establishment, exercise or defence of any legal claim.
10. Contacts and notices
If You have any concern about privacy or want to contact Our data controller(s) please contact Us with a thorough description, and We will try to resolve it. You may also contact Our Grievance officer or Data Protection Officer at the addresses below:
1. Grievance officer:
Name: Aarushie Sethi
E-mail: contact@third-unicorn.com
2. Data Protection Officer
Name: Aarushie Sethi
E-mail: contact@third-unicorn.com
10A. Process of Grievance Redressal
Any person having a grievance in relation to this Privacy Policy may furnish the grievance, at any time, to the above-mentioned personnel.
An acknowledgement of the grievance will be issued and generated by the Company for the benefit of the complainant within 24 (twenty four) hours of it being furnished for information and record.
We may reach out to You for further information and details on receipt of the complaint/queries/concerns by the Company. We will make all endeavours to resolve the complaint as soon as possible.
The manner of grievance redressal shall have the following arrangement: -
• the Company shall address the grievance and inform the complainant of its decision within 15 (fifteen) days of the registration of the grievance;
• if the decision of the publisher is not communicated to the complainant within the stipulated 15 (fifteen) days, the grievance shall be escalated to the contact@third-unicorn.com, handling grievance redressal committee at the Company.
11. Cookies
11.1 We use cookies, pixels, and other similar technologies (collectively, "Cookies") to recognize Your browser or device, learn more about Your interests, provide You with essential features and services, and for additional purposes, including:
1. Recognizing You when You sign in to use Our offerings. This helps provide personalized content and other customized features and services.
2. Keeping track of Your specified preferences, honouring Your likes and dislikes, such as Your language and configuration preferences.
3. Conducting research and diagnostics to improve Our offerings.
4. Preventing fraudulent activity
5. Improving security.
6. Delivering content, including ads, relevant to Your interests on Our Platforms and/or third-party sites.
7. Reporting to measure and analyse the performance of Our offerings.
11.2 Cookies are essential for some features of our service. If You block or reject our Cookies, You might not be able to use certain offerings that require You to sign in, or You might have to manually adjust some preferences or language settings every time You visit the Platforms. Approved third parties may also set Cookies when You interact with Our offerings.
11.3 You can manage browser Cookies through Your browser settings. The 'Help' feature on most browsers will tell You how to prevent Your browser from accepting new Cookies, how to have the browser notify You when You receive a new cookie, how to disable Cookies, and when Cookies will expire.
11.4 If You do this, however, You may have to manually adjust some preferences every time You visit a site and some features and services may not work.
11.5 We do not use cookies to save Personal Information for unauthorized uses.
12. Limitation of Liability
To understand the limitation of liability applicable on ‘Fund My Staff’, please refer to the Terms & Conditions.
All such information described above, shall be deemed to be transmitted/given access to or uploaded with Your consent and without any coercion.
The Company shall also not be liable to You for any action or omission of Our customer or third party including their non-adherence to the provisions of the DPDP Act and any applicable law as amended from time to time.
13. Governing Law and Dispute Resolution
The governing law and dispute resolution shall be as provided under the Terms & Conditions.
14. Severability
Each paragraph of this Privacy Policy shall be and remain separate from and independent of and severable from all and any other paragraphs herein except where otherwise expressly indicated or indicated by the context of the Privacy Policy.
The decision or declaration that one or more of the paragraphs are null and void shall have no effect on the remaining paragraphs of this Privacy Policy.
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