Privacy Policy

Effective Date: September 25, 2025

Thank you for choosing to use Haraka Loan (hereinafter referred to as "we" or "this application"). To protect your rights, this document explains how we collect, use, store, and protect your personal information. Please read this privacy policy carefully before using.

1. Types of Information We Collect and Its Uses

1. Personal Information

(Including ordinary personal data and sensitive personal data, according to India's Digital Personal Data Protection Act (DPDPA, 2023) and relevant regulations)

• Mobile number Usage: For account registration, identity verification, and contacting you. Legal basis: Performance of contract or your consent.
• Name, ID number, date of birth, gender, place of birth, residence, marital status, education level Usage: For identity verification, credit assessment, and contract fulfillment. Legal basis: Necessary for contract and legitimate interests (fraud prevention and ensuring service security).
• WhatsApp, email Usage: For communication and notifications. Legal basis: Your consent or contractual requirements.
• Facial data (biometric data) "Sensitive personal data" usage: Only for facial recognition verification to ensure account security. Legal basis: Your explicit consent, ensuring lawful data processing.
• Device information (such as ad ID, device name, system version, MAC address, IP address, UUID/IDFV, etc.) Usage: For device identification, optimizing app performance, risk monitoring, and fraud prevention. Legal basis: Legitimate interests (risk control) and your consent.
• Location information Usage: For providing localized loan services and risk assessment. Legal basis: Compliance with Indian regulations and your consent.
• Work-related information (company address, company name, phone number, monthly income) Usage: To verify employment background and evaluate repayment capacity. Legal basis: Contract fulfillment and legitimate interests.
• Contact person information (name, relationship) Usage: For emergency contacts and anti-fraud purposes. Legal basis: Your explicit consent and legitimate interests.

2. Permission Requests and Usage Explanation

By agreeing, we will obtain the following permissions:

• Camera permission Usage: For profile photo authentication, facial recognition verification to ensure account security.
• Album (storage) Usage: To upload ID documents and profile pictures for identity verification.
• Location information Usage: For offering regional matching and risk assessment.
• Contacts Usage: For emergency contact verification and anti-fraud.

3. Storage and Protection of Information

We will implement security measures and procedures aligned with international standards (such as ISO/IEC 27001) and approved by the Indian central government, including technical and administrative measures, to protect your personal data from unauthorized access, disclosure, alteration, or destruction. Payment data will strictly comply with RBI regulations on localization, meaning all payment data will be stored within India and not transferred abroad. We will regularly audit security measures' effectiveness.

4. Sharing, Disclosure, and Third Parties

Except as required by law or with your authorization, we will not disclose your personal data to third parties.
- Third-party partners include fraud detection services, cloud service providers, and payment gateways. These partners will provide credit evaluation, risk control, technical support, etc., under data processing agreements to ensure your data security.
- If mandated by the Indian central government or relevant regulators, or as required by law, we may disclose your information.

5. Data Transfer

We may transfer your personal data to our servers in accordance with India's DPDPA and related laws. Data transfers will follow notices from the Indian government (such as blacklist systems) and international standards (like Standard Contractual Clauses), with necessary safeguards to protect your data. Note: Payment data must be stored domestically in India as required by RBI and is prohibited from leaving India.

6. Your Rights

According to India's DPDPA and GDPR, you have the following rights:
- Access your personal data: You can query the data we hold about you at any time;
- Correct inaccurate or incomplete data;
- Request data deletion ("Right to be Forgotten"), when no longer needed for legal or contractual purposes;
- Restrict data processing, particularly during disputes;
- Data portability: Request transfer of your data in a structured, commonly used format to yourself or a third party;
- Object to data processing: Oppose processing based on legitimate interests or purpose in certain situations;
- Withdraw consent: You can withdraw your consent at any time, which will stop relevant processing unless legally required.
- Automated decisions: You have the right to obtain human intervention if automated decision-making affects you.
You can exercise these rights by contacting our support email support@rosebuduvl.com or via the application.

7. Data Retention Period

We will retain your personal data only as long as necessary for the purposes outlined in this policy or as required by law:
- Account-related info: For the duration of your account validity plus the legally mandated storage period (typically 1 year);
- Transaction and payment records: At least 1 year or as mandated;
- Sensitive data such as biometric info: Deleted immediately after collection or when no longer needed, unless required by law.

8. Cookies and Similar Technologies

We use cookies and similar technologies to improve user experience. You can manage or disable cookies through your browser settings.

9. Protection of Minors

We do not intentionally collect personal data from minors under 18 without explicit parental or guardian consent. If we find minors have provided data, we will delete it immediately.

10. Policy Updates Notification

We may update this policy based on law, regulation, or business needs. Changes will be announced within the app, and prior notice will be given before they take effect.

11. Regulatory Authorities and Complaints

If you have questions or complaints regarding your personal data processing, you can contact us:

Developer: Rose Bud Udyog & Viniyog Limited
Address: 33, Tollygunge, Circular Road 700053 Kolkata
Email: support@rosebuduvl.com