The following capitalised terms shall have the meanings assigned to them as under:
“HDFC Bank” or “Bank” shall mean HDFC Bank Limited having its registered office at Senapati Bapat Marg, Lower Parel (West), Mumbai 400013, Mumbai, India.
“Product(s)” shall mean the products and services of HDFC Bank, including where the initiation of any request, application or transaction is through us or any service provider of the Bank or through any Processing Entity or where HDFC Bank is acting as distributor or agent or acting under any referral arrangement for products or services of any other person or as an intermediary or a sponsor bank.
“Specified Purposes” shall collectively mean purposes of credit assessment, risk assessment, risk analysis, obtaining credit information reports, scores, scrubs, fraud checks, fraud detections, fraud prevention, detecting and preventing crime including crime/ terror funding, detecting malpractices or discrepant documents or information, prevention of misuse, assessment of credit worthiness, financial standing, due diligence, background check, physical and other inspections, verifications, obtaining any reports for any of the above, KYC/ AML checks, customer service, monitoring, collections, default detection, default prevention, default investigation, recovery, any legal proceedings, actions, enquiries, investigations, pursuing any remedies, enforcing rights, reporting including credit reporting, KYC reporting, default reporting, filing, perfections etc., whether any of these are undertaken internally by the Bank or through any of its Processing Entities including us, as applicable, or through a combination of multiple options.
Who we are
Throughout this document, “we”, “us”, “our” and “ours” or any cognate variations thereof refer to Credilio Pro,
Website : http://www.credilio.in
The personal data collected or received falls into various categories as under:
Out of the aforesaid data points, the following are ‘sensitive personal data or information’:
Provided that, any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as ‘sensitive personal data or information’.
Any of the aforesaid data (whether personal data or sensitive personal data or information), information, know your customer (KYC) related data, any derivative thereof (“Derivative Data”) like any credit scores or behavioural projections, profiling, analytical results, reports (prepared by us or others) including through any algorithms, analytics, software, automations, profiling etc., and whether such derivative is from the information collected from you or in combination with any other information sourced from any other person, database or source whether by us or HDFC Bank or others, shall collectively be referred to as “Data” and any part of the process relating to arriving at the Derivative Data as above, whether through internal or external sourcing, shall be referred to as “Derivation”.
When and how your Data is collected?
We and/or HDFC Bank may collect or possess the Data through any of the following:
[Our apps may be required by you to delete/ forget the Data submitted by you on such App which is specified as ‘Non-Mandatory Data’ during the application process for a digital lending Product (“Non-Mandatory Data”) (however subject to any contrary legal/ regulatory requirements), by following the process in this regard.]
How is your Data processed?
Purposes of processing Data
The processing of the Data may be done by HDFC Bank (directly or through its service providers including us to the extent allowed by HDFC Bank) or any of the Processing Entities for any of the following purposes, and you agree and consent to the same:
The purposes where it has been expressly specified above that such purpose is a non-mandatory purpose, shall be referred to as “Non-Mandatory Purposes”.
The way HDFC Bank (directly or through its service providers including us to the extent allowed by HDFC Bank) analyses personal information in relation to the Products including applications, credit decisions, determining your eligibility for the Products, may involve automated profiling and decision making, this means that HDFC Bank may process your Data using software that is able to evaluate your personal aspects and predict risks or outcomes as also where the decision making may be automated.
HDFC Bank may, directly or through us or through its service providers, also carry out automated anti-money laundering and sanctions checks. This means that it may automatically decide that you pose a fraud or money laundering risk if the processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct, is inconsistent with your previous submissions, or you appear to have deliberately hidden your true identity.
Who we share your Data with?
We may share the Data with the following persons and/or in the following circumstances:
HDFC Bank (either directly or through its service providers) may share the Data with the following persons and/or in the following circumstances:
For further information, please refer to the Products’ specific terms and conditions and application form.
Period of storage of the Data
[Implications of not providing Data or Withdrawing Consent
Reasonable security practices and procedures
[●] is ISO 27001:13 compliant. HDFC Bank is ISO 27001:13 compliant. We and HDFC Bank seek to use reasonable organizational, technical and administrative measures to protect Data within our respective organizations. However, if you have reason to believe that your interaction with us/ HDFC Bank is no longer secure, please immediately notify us/ HDFC Bank in accordance with the ‘How to contact us/ HDFC Bank’ section.
Links/ Re-direction to Other Websites/ Platforms
From time to time, our/ HDFC Bank’s website/ webpage/ platform/ apps may contain links or have a mechanism of re-direction to and from other websites/ webpages/ platforms/ apps of other networks, advertisers, affiliates and Processing Entities. If you follow a link or such re-direction to any of these websites/ webpages/ platforms/ apps, please note that these websites/ webpages/ platforms/ apps may have their own privacy notices and that HDFC Bank and we do not accept any responsibility or liability for any such notices. Please check such notices, where available, before you submit any Data to these websites/ webpages/ platforms/ apps.
Right to review
Please note that the accuracy of the Data provided is essential, among others, for the provision of Products to you. It is therefore mandatory that you ensure the accuracy and completeness of all Data disclosed or shared. Without prejudice to any rights and remedies of the Bank under any contract in this regard, you shall be able to review the Data that you had provided and correct or amend as feasible any such Data which you find to be inaccurate or deficient. You may do this by following the process prescribed by HDFC Bank in this regard. For knowing the process you may contact HDFC Bank.
Provided that HDFC Bank/ we shall not be responsible for the authenticity of the Data supplied by you to us / HDFC Bank or any other person acting on behalf of HDFC Bank.
How to contact us/ HDFC Bank
You may contact our Privacy Contact at Mr. Avishek Gupta, by email at email@example.com by phone at 022-49616121 (between 10.00 AM to 6.00 PM from Monday-Friday)
You may contact HDFC Bank’s Privacy Contact at firstname.lastname@example.org