LTCV CREDIT PRIVATE LIMITED – PRIVACY POLICY

Last Updated: 31st July 2025

PLEASE READ THIS POLICY CAREFULLY

This Privacy Policy ("Policy") explains how LTCV Credit Private Limited ("LTCV", "we", "us", "our", "Company") collects, stores, uses, transfers and processes your personal data in connection with providing you loan services ("Services") through our platform. We may revise this Policy from time to time. If you do not agree with any part of this Policy, please discontinue using our Services immediately. For any concerns regarding your data, please contact our grievance officer.

1. DATA COLLECTION AND USAGE

a. Personal Information You Provide

Data Type	Information Collected	Purpose
Basic Details	Name, phone number, email ID, PAN, date of birth, address, pin code	Loan processing, KYC verification, customer support, communication
Financial Information	Bank account details, IFSC code, income details, employment information, bank statements	Loan eligibility assessment, disbursement, repayment processing
KYC Documents	Aadhaar number, PAN card, address proof, income proof, employment verification documents	Identity verification, compliance requirements
Income Verification Data	Salary slips, bank statements, income tax returns (ITRs), EPFO data, employer details	Income verification, risk assessment, loan eligibility determination
Mobile Permissions	Camera, microphone access (one-time permission)	Document capture, video KYC verification

b. Data Collected from Service Usage

Data Type	Information Collected	Purpose
Transaction Data	Loan amount, interest rate, EMI details, payment history, transaction dates	Loan servicing, payment tracking, account management
Usage Data	Website interaction patterns, device information, browser type, access logs, call recordings	Service improvement, customer support, fraud prevention
Communication Records	Customer service interactions, support queries, feedback	Quality assurance, dispute resolution, service enhancement

c. Information from Third Party Sources

Source Type	Information Accessed	Purpose
Credit Bureaus	Credit history, credit score, loan history	Credit assessment, fraud detection, risk evaluation
Account Aggregators	Bank statements, transaction history	Income verification, financial assessment
Employment Verification	Employment status, salary details, EPFO records	Income and employment verification

2. HOW WE USE YOUR DATA

a. Primary Purposes

Loan Processing: Assessment of loan eligibility, credit evaluation, and loan approval
KYC & Compliance: Identity verification, regulatory compliance, anti-money laundering checks
Service Delivery: Loan disbursement, EMI processing, account management
Customer Support: Resolving queries, providing assistance, handling complaints
Communication: Service updates, payment reminders, promotional communications
Risk Management: Fraud detection, credit monitoring, collection activities
Income Verification: To assess and validate your income and financial standing through documents submitted by you or obtained from third-party sources, in order to determine your eligibility and repayment capacity for the loan.

b. Legal Basis for Processing

We process your data based on:

Your explicit consent
Contractual necessity for loan services
Legal and regulatory compliance requirements
Legitimate business interests

3. DATA SHARING

We do not sell your personal data. We share your information only with the following parties for specified purposes:

a. Technology Service Providers (TSPs)

Service Provider	Role	Purpose	Data Shared
Swiffy Labs	LOS/LMS Provider	Loan origination and management system	Loan application data, customer information, transaction records
Digitap	Verification TSP	PAN verification, employment verification	PAN details, employment information
Digio	Digital Services	E-NACH registration, VKYC, e-signature services	KYC documents, bank details, identity information

b. Financial Service Providers

Service Provider	Role	Purpose	Data Shared
Cashfree	Payment Gateway	Account verification, payment processing	Bank account details, transaction information
IDFC Bank	Banking Partner	Loan disbursement, collection services	Account details, loan information
HDFC Bank	Banking Partner	Loan disbursement, collection services	Account details, loan information
Finvu	Account Aggregator	Banking statement access	Bank account information, transaction history
Finfactor	TSP – Aggregator	Account verification services	Account details for verification

4. CREDIT AND RISK ASSESSMENT

Service Provider	Role	Purpose	Data Shared
Experian	Credit Bureau	Credit reports, fraud checks	Personal details, loan history, credit information
CIBIL	Credit Bureau	Credit scoring, fraud detection	Personal details, financial information
Karza / Perfios / Digio / Digitap (as applicable)	Income Verification Services	Extraction and validation of income details from ITRs, salary slips, EPFO records, and bank statements	Income documents, employer data, financial information

a. Communication Partners

Service Provider	Role	Purpose	Data Shared
Karix	Messaging Service	SMS, communication services	Contact details for service communications
Vodafone Idea	Telecom Service	SMS delivery	Phone numbers for communication

b. Infrastructure Partners

Service Provider	Role	Purpose	Data Shared
Amazon Web Services	Cloud Provider	Secure data storage and processing	Encrypted data for cloud services

c. Regulatory and Legal Sharing

We may share your information with:

Government authorities and regulatory bodies as required by law
Law enforcement agencies when legally mandated
Courts and tribunals for legal proceedings

5. YOUR RIGHTS

You have the following rights regarding your personal data:

Right to Access
Right to Rectification
Right to Withdraw Consent
Right to Data Portability
Right to Deletion
Right to Restrict Processing

6. DATA SECURITY

a. Security Measures

End-to-end encryption for data transmission
Secure data storage with access controls
Regular security audits and vulnerability assessments
Employee training on data protection
Multi-factor authentication systems

b. Data Breach Response

Detect and assess security breaches
Contain and mitigate risks
Notify affected users and authorities as required
Implement corrective measures

7. DATA RETENTION

a. Retention Periods

Active Loan Period: Throughout the loan tenure and servicing period
Post-Closure: 7 years after loan closure for compliance requirements
KYC Documents: As per RBI guidelines and regulatory requirements
Communication Records: 3 years for customer service purposes

b. Secure Deletion

Data is securely deleted after retention periods expire, except where longer retention is required by law.

8. CONSENT MANAGEMENT

a. Obtaining Consent

Clear consent checkboxes during onboarding
Detailed explanation of data usage purposes
Granular consent options where applicable

b. Managing Consent

Review your current consent settings
Modify or withdraw specific consents
Access consent history and changes

Note: Withdrawing certain mandatory consents may affect our ability to provide loan services.

9. CHILDREN'S PRIVACY

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from minors. If we discover that a minor has provided personal information, we will delete such information immediately.

10. CROSS-BORDER DATA TRANSFERS

If we transfer your data outside India, we ensure:

Adequate protection mechanisms are in place
Compliance with applicable data protection laws
Contractual safeguards with data recipients

11. COOKIES AND TRACKING

We use cookies and similar technologies to:

Enhance user experience
Analyze website usage
Provide personalized services
Prevent fraud

You can manage cookie preferences through your browser settings.

12. COMMUNICATION PREFERENCES

a. Service Communications

We may contact you via calls, SMS, email, and push notifications for:

Loan servicing updates
Payment reminders
Security alerts
Regulatory communications

b. Marketing Communications

We may send promotional content with your consent. You can opt-out at any time through:

Unsubscribe links in emails
SMS opt-out instructions
Account settings
Contacting customer support

13. UPDATES TO THIS POLICY

We may update this Policy periodically. We will:

Notify you of material changes
Post the updated policy on our website
Obtain fresh consent where required by law

Continued use of our services after updates constitutes acceptance of the revised Policy.

14. GOVERNING LAW

This Policy is governed by Indian data protection laws, including:

Information Technology Act, 2000
Information Technology (Reasonable Security Practices) Rules, 2011
RBI Guidelines on Digital Lending
Other applicable regulations

15. CONTACT US

LTCV Credit Private Limited

Address:
1st Floor, No.10, 6th Main, 8th B Cross, Jeevan Bheema Nagar, Bangalore, Karnataka, 560075

Website: https://www.ltcv.credit/

Data Protection Officer: Shashank Sharma

Email: data@ltcv.credit

Phone: 8884107773

Grievance Redressal Officer: Santosh Goteti

Email: grievance@ltcv.credit

This Privacy Policy is effective from 2nd June 2025 and supersedes all previous versions.