PRIVACY POLICY

This Privacy Policy, (hereinafter "Privacy Policy" and/or "Policy"), is being made available as per the requirements of Rule 4(1) of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2021. This rule mandates the publication of a Privacy Policy to govern the management and handling of personal information, including sensitive personal data or information.

Ensuring privacy and adhering to data protection regulations are matters of significant importance for Finja Lending Services Limited (hereinafter "Finja" or "we"). This Policy outlines the overall guidelines that govern the gathering of personal data by Finja via its online platform (the "Platform"). By utilizing the Services offered by Finja and engaging in activities involving sensitive personal data and information, you are giving your consent for the utilization and disclosure of your personal information in accordance with this Privacy Policy and the associated Terms & Conditions. This Privacy Policy is an integral part of and is subject to the Terms & Conditions of the Platform. For the purpose of this Privacy Policy, the individuals using the Services or accessing our Platform may include customers utilizing the Services through our Platform

By using the Platform, you are consenting to our collection and utilization of your personal information as outlined in this Privacy Policy. You affirm your agreement to the provisions stated in this Privacy Policy and provide us with your irrevocable consent to collect your personal information.

Finja reserves the right to change, modify, add, or remove portions of this Privacy Policy at any time for any reason. In case, any changes are made in the Privacy Policy, we shall update the same on the Platform. Once posted, those changes are effective immediately, unless stated otherwise. We encourage you to periodically review this page for the latest information on our privacy practices. Continued access or use of the Services constitute your acceptance of the changes and the amended Privacy Policy.

We kindly request you to thoroughly review this, Policy. By selecting the checkbox or clicking the "Agree" button, you acknowledge and fully agree to all the provisions outlined in this Policy. If you do not consent to this Policy or any of its components, we kindly request you to refrain from using or accessing the Platform.

1. Introduction

1. This Privacy Policy of Platform applies to personal information collection and use while you, install, activate, and use Platform, the system registers you as a user on the Platform (the "User Account").
   Note: this Privacy Policy is subject to modification at any time, without prior notice. It is your responsibility to regularly review this Privacy Policy in order to stay informed about any updates or revisions.
2. This Policy encompasses interactions with Finja that occur as part of Finja's business operations, such as:
   1. Accessing our Services through any Platform;
   2. When entering any promotion;
   3. When using our customer service;
   4. Generally enquiring about our Services.
3. You acknowledge and agree that it is your responsibility to provide Finja with truthful, accurate, current, non-misleading, and complete information when providing any information. You also agree not to misrepresent your identity, or any details related to your account. It is important that you keep your account information up to date and accurate. You confirm that any phone number you provide belongs to you or that you have the authorization to provide it. In the event of any changes to your address or phone number, you must promptly notify us. We may also update your address if we are notified by any reliable sources.
4. By providing any personal data of third parties (such as guarantors or emergency contact numbers), you affirm that you have informed these third parties and obtained valid consent from them, or you have a legitimate interest that allows you to provide their personal data to Finja. This is necessary for Finja to process their personal data for the purposes stated in this Privacy Policy. Furthermore, you are expected to assist Finja in obtaining valid consent from these third parties. Therefore, if you provide personal data of third parties, Finja assumes that you have obtained their consent or possess the necessary legitimacy to do so, and that the third party has been informed about the information contained in this document.

2. Type of personal data processed

1. "Personal information" refers to any data that can be used to identify, locate, or contact an individual, either on its own or when combined with other personal or identifying information. This includes information that you provide when registering and creating a User Account with us. Examples of personal information include, but are not limited to, your name, email address, phone/mobile number, country/city of residence, job status, company name, salary, payday, marital status, family address, SIM card details, age, gender, username, and password. Finja has the ability to associate different categories of information with one another, and such combined information will be treated as personal data in accordance with this Policy for the duration of its combination.
2. All data that You provide will be securely uploaded and stored on Our server in an encrypted format through the interface. Finja is committed to maintaining the confidentiality of Your data and will not disclose it to any unauthorized third parties or beyond what is necessary for the provision of Services to You.
3. We gather information during the registration process on the Platform, which includes the information and data You provide when completing the registration form. Additionally, any information and data shared with us during any form of communication, such as email, chat, or helpline interactions, will also be collected.
4. We collect information and data provided by you when you register to utilize Services through the Platform, register on the site, subscribe to our Services (e.g., buy now pay later services), or report any issues with the Platform.
5. We may obtain your information from external sources and third-party service providers, including banks, credit bureaus (credit reports), and commercially available geographic and demographic data (provided by third parties).
6. Finja, along with its authorized third parties, has the capability to collect, store, and process personal information for the purpose of delivering our services, and facilitating the use of the Platform
7. Personal data shall be obtained and updated through means of:
   1. Remote or electronic methods;
   2. Through the use of other technologies that allow data to be collected automatically or simultaneously at the time the data subject contacts Finja
8. As you make use of the Platform, we gather and securely store the personal information you provide us with. We explicitly seek your permissions to obtain the necessary information, ensuring transparency and consent in the collection process. This allows us to maintain accurate and up-to-date records of the information you provide.

3. Non-personal information

Including but not limited to, This may encompass various details, such as your Internet Protocol (IP) address, operating system, browser type, and internet service provider. It is important to note that this type of information does not personally identify the visitor or customer. These data points are collected for analytical purposes and to enhance the overall User experience.

4. Technical information

We may collect information about the mobile device you utilize, such as the specific type of device, unique identifiers like IMEI or serial numbers, details pertaining to the SIM card being used, mobile network information, operating system of your device, the browser type you employ, and even the device's location and time zone settings. These details fall under the category of device information and are gathered to enhance the functionality and experience of our Services.

5. Customer Information

Information stored on your device, including camera, videos or other digital.

6. Log Information

Details of your use of Platform including, but not limited to traffic data, location data, Weblogs, and other communication data.

7. Location

Finja may also use GPS technology or other location services to determine your current location.

8. Images and Files

1. We gather your National Identification Card (CNIC) image and live photo, which are generated by Finja itself. This information will be securely uploaded to our server in an encrypted format. It is important to note that these entities involved in the handling of this information are bound by confidentiality obligations and operate within the legal limitations imposed by relevant laws in the jurisdiction where the data is collected, stored, processed, or transmitted.
2. By using the Platform, you acknowledge and consent to the collection, storage, and processing of all the aforementioned information, including any third-party supplied data, as part of your interaction with Finja. You agree that this personal data will be utilized for the purpose of providing the Services we offer. Furthermore, you consent to our collection of any modifications or updates made to this information, ensuring the accuracy and relevance of your data for our Services.

9. Purpose for your personal data and the basis for doing so

The purposes for collecting and processing personal data are related to the execution of a contract in which the individual is involved or to carry out procedures requested by the individual prior to entering into a contract with Finja. These activities are aimed at fulfilling contractual obligations and facilitating the necessary steps before entering into a formal agreement with Finja

1. Know Your customer process (KYC), including, without limitation, the identification of your identity, the fight against fraud, money laundering and terrorist financing.
2. Debt recovery and the related payment process, including without limitation contact with you (by us, our authorized organization, or any individual or legal entity purchasing debt from us) in the event of a debt default.
3. Follow your instructions in relation to Services contracted by you and to verify the transactions on any of your Services.
4. Purposes based on your consent when registering on Platform:
   1. Sending commercial communications electronically
   2. Respond to requests and messages sent by you

10. Purposes based on compliance with current laws.

In order to safeguard against fraud, money laundering, and ensure the security of customer transactions associated with the Services Finja offers, Finja undertakes measures to verify and authenticate such transactions. These efforts are implemented to protect both Our customers and Finja from any illicit activities and to maintain a secure environment for financial transactions.

11. Tracking

We gather certain information about you by tracking your activities on the Platform. This data is utilized for internal research purposes, enabling us to understand our users' demographics, interests, and behavior. The insights derived from this analysis aid us in enhancing our Services, ensuring user protection, and delivering an improved experience. This information is compiled and analyzed in an aggregated manner, respecting User privacy. We collect your Internet Protocol (IP) address. If you make a purchase through the Site, we gather data pertaining to your buying behavior. We retain this information for necessary purposes, including resolving disputes, providing customer support, and troubleshooting issues, in compliance with applicable laws and regulations. If you engage in personal correspondence with us, such as via emails or letters, or if other users or third parties share information about your activities or posts on the Platform, we maintain a specific file containing such correspondence for reference and record-keeping purposes.

Cookies are small data files that a website stores on your computer. We will use cookies on our website similar to other lending websites/sites and online marketplace websites / sites. Use of this information helps us identify you in order to make our Site 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 Site. If you choose to make a purchase through the Site, we collect information about your buying behaviour. We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.

12. Use of Your personal information

1. The information we collect is utilized to evaluate the eligibility of customers for financial Services. To facilitate payment processing, including payments, repayments, and money transfers to your User Account, we may engage the Services of a third-party payments services provider or payments processing company.
2. We use the information you provide to enhance your experiences and interactions with Finja. This data is instrumental in delivering, supporting, improving, protecting, analyzing, and billing for our Services. It allows us to communicate with you regarding your Service, market our offerings, detect and prevent fraudulent activities, engage in advertising initiatives, and conduct research. When you make a purchase, subscribe to our newsletter, participate in surveys or marketing communications, browse the Platform, register for a User Account, or download and register on our Site, we utilize the information collected in the following manners to optimize your experience:
   1. Tailor your experience and provide you with content and Service offerings that align with your interests and preferences.
   2. Enhance the functionality and performance of our Platform to ensure a seamless and improved user experience.
   3. Improve our ability to address your customer service inquiries and provide timely and effective support.
   4. Request ratings and reviews of our Service to gather feedback and enhance the quality of our offerings.
   5. Follow up with you after any form of communication, be it through live chat, email, or phone, to ensure that your needs have been addressed and to maintain a satisfactory level of customer engagement. This means we may:
      1. Maintain a comprehensive record of the Service you avail from us, ensuring accurate documentation of your Service history.
      2. Send you important service-related messages to provide updates, confirmations of orders, and notify you about any changes that may impact your Service. This includes informing you about planned infrastructure work or necessary repairs.
      3. Enable you to create and securely log in to User Accounts managed by us, ensuring a seamless and personalized user experience.
      4. Process payments efficiently, ensuring that your payments are successfully received and credited to your account.
      5. Share necessary information with relevant entities or third-party service providers if it is essential for delivering the Service you have ordered. Additionally, we may also share information with other communications providers if you are purchasing Services from both parties.
3. Furthermore, we utilize the following information to deliver Services and oversee your account management:
   1. We require your contact details and other pertinent information to verify your identity and facilitate effective communication with you. This encompasses your Personal Information and other essential credentials.
   2. Your payment and financial information are essential for processing transactions and ensuring seamless financial operations.
   3. We maintain records of your communications with us, including emails, webchats, and phone calls. Additionally, we retain any preferences or settings you specify to ensure personalized and satisfactory interactions.
   4. We may collect information from cookies installed on your connected devices to enable the provision of our Services in an efficient and optimized manner.
4. We may disclose your personal information to any entity within our corporate group, including our subsidiaries, ultimate holding company, and its subsidiaries.
5. In certain circumstances, we may disclose your personal information to local or international law enforcement agencies, regulatory authorities, or government agencies if we have a good faith belief that such disclosure is reasonably necessary to enforce our Terms & Conditions and/or this Policy, or to assist in the prevention, detection, investigation, or prosecution of criminal activities or fraud.
6. We utilize your data for compiling statistics related to our user base or financial Services. In some cases, we may share this information with third parties for statistical purposes, ensuring that the data is always anonymized.
7. We may employ other third-party companies to monitor website traffic, which may involve the storage of customer information. Even when using external organizations, we maintain control over your personal information and implement stringent safeguards to ensure its proper protection.

13. Credit Bureau Reporting.

You authorize us to investigate your creditworthiness and to obtain consumer reports about you in connection with the right to use our Services and for as long as your User Account is open and/or your BNPL Agreement is in effect. You authorize us to use such information and consumer reports for any purpose, including without limitation, to evaluate the Services provided by us, review your User Account, to review whether changes should be made to the Terms & Conditions of your User Account, and to consider you for offers for our Services. You represent to us that all information associated with your identity held by any national credit bureau is true and correct in all material respects and that there has been no material adverse change which is not reflected therein.

14. Security Practices

1. We have implemented various security measures to protect your personal information from unauthorized access or disclosure. These measures include technical, operational, managerial, and physical controls. Your personal information is stored in secure networks and is only accessible by a limited number of authorized individuals who are bound by confidentiality obligations. We have implemented an Information Security Management System (ISMS), which encompasses a comprehensive set of policies and procedures to manage information risk within our organization. This framework covers legal, physical, and technical controls to ensure the security and protection of your data.
2. We work hard to protect from unauthorized access, alteration, disclosure or destruction of information we hold, including:
   1. We use encryption to keep your data private while in transit;
   2. We offer security feature like an OTP verification to help you protect your account;
   3. We review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems;
   4. We restrict access to personal information to our employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations;
   5. Compliance & Cooperation with Regulations and applicable laws;
   6. We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it.
3. The data and information we collect from you may be transferred to a destination where it will be stored and processed (the server destination online/offline shall at all times be within the jurisdiction of Islamic Republic of Pakistan). Our staff members at the destination may be involved in fulfilling your requests and providing you with the necessary Services. By providing your personal data, you consent to the transfer, storage, and processing of your information. We will take all reasonable measures to ensure that your data is treated securely and in compliance with the principles outlined in this Policy.
4. We have implemented security measures to restrict access to personal information on a need-to-know basis. Our employees adhere to a code of conduct and confidentiality policies that require them to maintain the confidentiality of personal information. These measures are in place to ensure the protection and privacy of our personal data.
5. . We strive to maintain the security of the Platform; it is important to note that there may be circumstances beyond our control where security risks could arise. Therefore, any personal information transmitted to or from our Services is done at your own risk. However, we are committed to taking all reasonable efforts to ensure the security of your information. We implement reasonable security measures to safeguard your personal information against hacking and the dissemination of viruses.
6. We have provided you with a password to access our Platform or you have chosen your own password, it is your responsibility to keep it confidential. We kindly ask you not to share your password with anyone. While we will make every effort to protect y our personal data, it is important to note that the transmission of information over the internet is not completely secure. Therefore, any transmission of data to our Platform is done at your own risk. Once we receive your information, we will implement procedures and security features to try to prevent unauthorized access to the best of our ability.

15. Forward Looking Statements

The Platform includes forward-looking statements that express our current perspectives on the operations and performance of our businesses. It is important to note that these statements are subject to certain risks and uncertainties, which may cause actual outcomes or results to differ from what is indicated. We are not obligated to publicly update or review these forward-looking statements, unless required by law or future developments prompt us to do so.

16. Privacy Controls

You have the ability to make choices about the information we collect and how it is utilized. Here are your options:

1. Delete your entire Site account: you can choose to delete your entire account on the Site.
2. Content removal request: In accordance with applicable laws, you can request the removal of specific content from our servers. To do so, you can reach out to our Grievance Officer in writing.
   We respect your choices and will strive to accommodate them to the extent permitted by law.

17. Consent To Electronic Communication

By creating a User Account and accessing Platform Services, you are agreeing to the terms outlined below, which serve as your consent to receive electronic communications regarding your User Account. By successfully providing your consent within the Platform, you confirm that you can access the information we have posted on the Site.

18. Categories of Communications.

By giving your consent, you acknowledge and agree to receive electronic communications pertaining to your User Account. These communications may include, but are not limited to, the following:

1. The initial disclosure statement or agreement governing your User Account.
2. Disclosures required by state, or local laws.
3. Billing statements if you have opted to receive electronic statements.
4. Letters, notices, or alerts regarding your User Account, including any updates or modifications.
5. Other disclosures, notices, or communications relevant to your User Account access, account maintenance, or collection activities.

Note that these electronic communications may contain your name and certain details about your User Account, such as your balance or payment due date. However, your full account number will not be included. It is important to be aware that these electronic communications may be accessible to individuals with authorized access to your User Account, the email address provided for communication, or the devices and software used to view your User Account information.

19. How to Withdraw Your consent

In order to apply for and use a User Account, it is mandatory for you to provide consent to receive electronic communications. If you have successfully created a User Account and decide to revoke your consent for future electronic communications, you must follow the process outlined in the User Account Agreement to close your User Account entirely and withdraw your consent. We do not impose any fees for processing the withdrawal of consent to electronic communications. Note that if you choose not to consent to electronic communications or later withdraw your consent, you will be unable to receive or access your User Account information. It is important to understand that the withdrawal of consent to electronic communications will only take effect after we have been given a reasonable period of time to process your request to cancel your User Account and provided that you have fulfilled all other requirements for closing your User Account.

20. How to update Your records

You agree to promptly update your e-mail address if a change occurs by updating your information through the Platform or by calling customer service.

21. Hardware and Software Requirements;

In order to access and retain electronic communications, you must have the following:

For mobile devices (phones, tablets, or other mobile devices with Internet browsing capabilities): Access to the Internet via dial-up, DSL, cable modem, wireless access protocol or equivalent SSL-enabled web browser that supports HTML 5, JavaScript, and CSS3 Sufficient electronic storage capacity on your mobile phone.

22. . Electronic Signatures:

You acknowledge that by clicking on the "Submit," "Apply," or similar button, you are indicating your intent to sign up for electronic communications and that this shall constitute your signature.

23. Law:

You acknowledge and agree that your consent to electronic communications is being given in relation to a transaction that involves interstate commerce and is governed by the Electronic Signatures in The Electronic Transactions Ordinance, 2002. Both parties, you and we, intend for the Act to apply to its fullest extent to validate our ability to conduct business and communicate with you through electronic means.

24. Important terms For Electronic Statements

In addition to the above, the following information applies:

Statement Inserts.

You shall receive statements through Pakistan mail, you may also receive any accompanying inserts electronically. If an insert contains legally required information, we may send you a paper copy of the statement along with the electronic version to ensure that you receive all necessary material. Any legally required insert that cannot be provided electronically will be sent to you through Pakistan mail.

Payment Information.

You must ensure that any and all repayments owed to Finja are made in a timely manner by or before the Payment Due Date. All details pertaining to payments owed including amount and due dates can be accessed through the User account dashboard. All payments may be made electronically and/or by mailing the due amount to Finja’s address. Payments made using a non-electronic payment method can take up to five days after receipt for the payment to be credited.

Returned E-mails.

In the event that emails notifying you about our account status are undeliverable, we may make efforts to contact you through alternative means, which could involve sending paper communications. However, please note that your inability to reach you will not affect the due dates, amounts owed, or any other aspects of your account with us. It remains your responsibility to stay informed and fulfill your obligations accordingly

SPAM Filters.

We will take necessary steps to ensure that our email notifications are not mistakenly marked as spam by relevant filter agencies. However, it is your responsibility to ensure that any spam filters in place recognize emails originating from us. If you do not receive our email notifications despite enrolling for electronic statements, please consult with your email account provider and check the settings of your email account's spam filter.

Account Delinquency.

We retain the right to discontinue electronic statements without prior notice if your account is not maintained in good standing.

Cancellation.

We retain the right to cease providing electronic statements to you at any time. We will give you advance notice of this change, except in situations where your account is delinquent.

25. Retention of Storage and Dat

1. We will retain your personal information for as long as it is necessary to fulfill a legitimate business purpose, such as providing Services to you, or as required by applicable laws, including tax and accounting regulations.
2. To ensure the security of your data, all individual credentials, information, and data will be encrypted during transmission and while stored. We will use strong encryption standards, internationally recognized, and published, including key length, algorithms, cipher suites, digital certificates, and protocols that are secure and not deemed vulnerable. Encryption keys will be stored with robust security controls in a highly secure and standard key store, in a non-exportable form.
3. Once We no longer have a legitimate business need to process your personal information, we will securely delete it from our systems.
4. The personal data we collect from individuals may be transferred to and stored at a destination within Pakistan. By providing your personal data, you consent to the transfer, storage, and processing of your information in accordance with this Policy.

26. Disclaimer

1. The software is provided "as is" and Finja makes no warranty of any kind, express or implied, by statute or otherwise, including but not limited to any implied warranties of merchantability, fitness for a particular purpose, title, or non-infringement. In no event shall we be liable for any damages whatsoever (including, without limitation, incidental and consequential damages, lost profits, or damages resulting from lost data or business interruption) resulting from the use or inability to use the Platform or its content whether based on warranty, contract, tort (including negligence), or any other legal theory, even if you have been advised of the possibility of such damages.
2. By using Platform, you agree that Platform, its affiliates, associated or related entities, employees, directors, shareholders, agents, and representatives shall not be held liable for any security breach that may result in unauthorized access to or disclosure of your information. To the fullest extent permitted by law, you agree to waive any rights to seek damages or hold Finja and its related entities responsible for any
3. Finja disclaims any warranty, representation, consideration, or assurance that the Platform Services or the network running the Platform Services will operate without error or interruption or will be free of vulnerability to intrusion or attack. Finja further disclaims any warranty, representation, consideration, or assurance that any security features included with the Services will be provided in real time. Finja disclaims all conditions, remedies, and warranties in and to the Services (whether express, implied, statutory, or otherwise), including any implied warranty of merchantability, fitness for a particular purpose, no infringement, satisfactory quality, non-interference, accuracy of informational content, or arising from a course of dealing, law, usage, or trade practice. Finja shall have no liability for your failure to comply with your responsibilities. This disclaimer and exclusion shall apply even if the express warranty fails of its essential purpose.

27. Marketing

We may reach out to you via email to share valuable information about the Services, and content that we believe may be relevant and interesting to you. If the applicable law requires us to obtain your consent before sending certain types of marketing communications, we will only send those communications after receiving your explicit consent. Rest assured that we respect your preferences and will abide by the regulations in place to ensure compliance and protect your privacy.

28. Disputes

This Agreement will be governed by and interpreted in accordance with the laws of the Islamic Republic of Pakistan. Any disputes related to this Policy will be subject to the Terms & Conditions of Finja, which include provisions on indemnification, limitations of liability, choice of law, and dispute resolution. We kindly request that you first submit any complaints regarding these matters directly to our customer services email for proper handling and resolution.

29. Contact Us

If you have any questions or suggestions about this Privacy Policy, please do not hesitate to contact us:

Contact Number: 042-111-113-575

30. Your Consent

1. By using the Platform or providing your information, you are giving your consent to the collection and use of the disclosed information in accordance with this Privacy Policy. This includes your consent for the collection, usage, sharing, and disclosure of your information as described in this Policy. If any changes are made to our privacy Policy, we will notify you by posting those changes on this page. This way, you will always be informed about the information we collect, how we use it, and when we disclose it
2. You have the right to revoke or restrict your consent at any time, in accordance with the terms of the Privacy Policy and general Terms & Conditions.