RKPF : RamKrishna Pure Finance

Company Privacy Policy

A. Purpose of Privacy Policy

The Privacy Policy (“Policy”) is an electronic record in the form of a contract formed under the applicable laws. This Policy does not require any physical, electronic or digital signature and is a legally binding document between you (as defined below) and RamKrishna Pure Finance Private Limited (“RKPF”), Non-Banking Financial Company (“NBFC”). This Policy is meant to ensure that the personal information shared by the Customer with RKPF is used fairly and lawfully and not used against the interests of the Customer by RKPF or shared with a third party expect in accordance with this Policy, applicable laws and with appropriate safeguards. This Policy explains how RKPF collects, uses, stores, protects and otherwise processes information relating to identifiable individuals (“Personal Information”). This Policy is applicable on all our users, , Customers who avail our services or visits the website of RKPF.

B. Definitions used in the Policy

“Customer” refers to all members who have taken a loan or any other service from RKPF or from any other bank/NBFC/Other financial institution through RKPF acting as agent/banking correspondent. This includes those members who have current loan outstanding and those who have taken a loan earlier, but have since repaid or have dropped out of the programme. Any co-applicant, guarantors and authorised representatives linked to our services are also included in the definition of Customer
“Information/Data” includes any financial and personal data collected from the members at the time of loan application, during the relationship or otherwise in connection with RKPF’s services. This includes, without limitation:-
- Financial information any data collected from the Customer regarding their businesses, income, expenses, loans outstanding, repayment history, guarantors, or collateral, banking details, credit bureau reports, and any information relevant for credit assessment, underwriting and servicing.
- Personal information includes any data collected from the Customer that is about their family, contact details, identity health declarations (where applicable), consumption behaviour, personal preferences, attitudes, beliefs or living conditions.
- Identification and KYC information such as PAN, Aadhaar number (wherever provided in accordance with law and with consent), voter ID, driving license, ration card, photographs, signature, video-KYC recordings and other officially valid documents and data used for know your Customer (KYC) and Customer due diligence (CDD) purposes.
- Digital / device information such as IP address, device identifiers, browser type, operating system, date and time of access, location data (where permitted), log data and other technical information when the Customer uses RKPF’s website or digital platforms.
- Transactional information such as loan application details, sanction terms, repayment schedule, payment history, account statements, communications with RKPF (including call recordings, SMS, email and other correspondence), complaints and queries.
“Records” are tangible object (such as physical files and documents) or digital information (such as electronic records, databases, emails and system logs) maintained by RKPF in connection with its Customers and operations.
“Records Management” is the practice of maintaining the records of an organisation from data collection stage till the data disposal stage. This includes: classification, storage, securing, access control and destruction or archival preservation of records.
“Credit Bureau” is an independent organisation that compiles information from credit grantors and other sources regarding individuals’ credit applications and payment behaviour, and provides such information to its members for purposes permitted by law.
“Processing” shall mean any operation or set of operations performed on personal information, including collection, recording, organisation, storage, adaptation, alteration, retrieval, use, disclosure, dissemination, alignment, combination, restriction, erasure or destruction.

Purpose Of Collection Of User Information

From time to time, RKPF may request and collect Customer Information/Data for the purposes described in this Policy. Such information may be collected from the following sources:

Directly from the Customer, including through loan application forms, KYC documents, interactions with RKPF staff, calls, emails, SMS, digital platforms or other communications.
From co-applicants, guarantors or referees provided by the Customer.
From credit bureaus and other financial institutions, in accordance with applicable law and membership rules.
From banks, payment service providers, collection agents and other partners involved in disbursal, repayment, collection or servicing of the Customer’s obligations.
From publicly available sources, government databases, regulators, statutory authorities and self-regulatory organisations, where permitted.
Automatically, when the Customer visits RKPF’s website or uses its digital platforms, through cookies, web beacons and related technologies, subject to applicable law.

RKPF collects and processes Customer information only for lawful purposes connected with its functions and activities as an NBFC. Without limitation, RKPF may collect, use, store and process Customer information for the following purposes:

for provision of personalised services such as informing Customers of existing and new services, offers and features, subject to Customer consent where required;
For receiving, processing and deciding upon loan or other facility applications, including carrying out KYC / CDD, risk assessment and underwriting.
For verifying, authenticating and / or updating the Customer’s KYC information, including Aadhaar number where provided, solely for the purpose of facilitation of extension of credit facilities and providing KYC services, in compliance with applicable law.
To enable the provision of credit facility services and other financial services to the Customer through RKPF’s branches or digital platforms or Head Office, and for activities and transactions that need to occur during the process of lending, including without limitation, generating and maintaining user profiles, providing personalized features, facilitating collection services, maintaining regular communications with the Customer concerning transactions the Customer initiates (such as requesting information or assistance, submitting a loan request, making payments, transferring funds, etc.).
To communicate necessary account, product and / or service-related information to the Customer from time to time, including statements, reminders, alerts and notices.
For grievance redressal purposes, including investigating and resolving complaints, queries and disputes;
For prevention and detection of fraud, money laundering, financing of terrorism and other unlawful activities, and for reporting to relevant authorities under the Prevention of Money Laundering Act and other applicable laws and regulations.
For improving RKPF’s products, services, processes and systems, including through analytics, research, surveys and Customer feedback.
For complying with applicable laws, regulations, directions and guidelines issued by the Reserve Bank of India (RBI) and other regulators, and for responding to lawful requests and orders of courts, law enforcement and other authorities.

RKPF processes personal information based on one or more of the following legal bases, as applicable: (a) the Customer’s consent, (b) necessity for entering into or performing a contract with the Customer, (c) compliance with legal obligations, and (d) legitimate interests of RKPF in operating and improving its business, balanced with the rights and interests of the Customer.

Aadhaar and KYC Specific Provisions

Provision of Aadhaar information by the Customer to RKPF is voluntary, unless otherwise mandated by law. Alternate KYC options may be provided where permitted.
RKPF will use Aadhaar-related information only for purposes permitted by applicable laws, including the KYC Master Directions, Prevention of Money Laundering Act, rules made thereunder and applicable UIDAI regulations / circulars.
RKPF will obtain explicit consent from the Customer, in the prescribed format where required, before accessing, authenticating or using the Customer’s Aadhaar information.
RKPF will not store, use or share Aadhaar information in any manner that is inconsistent with applicable law and regulatory directions.

Sharing Customer information to third Parties

RKPF respects the confidentiality of Customer information and will disclose or share such information only as described in this Policy, or as required or permitted by applicable law and regulation.

Disclosure/Sharing of Customer’s personal information only under the following circumstances
- As per the legal requirements or to comply with any applicable laws, regulations, order, direction or request of any court, tribunal, law enforcement agency, regulatory authority (including RBI) or self-regulatory organisation.
- As part reciprocal information exchange with other financial institutions (such as a credit bureau), in accordance with membership rules and applicable law.
- To process loans or other facilities with any other bank/NBFC/Other financial institution where RKPF is acting as agent/banking correspondent or partner.
- To RKPF’s group companies, affiliates, agents and business correspondents for purposes connected with providing services to the Customer, subject to confidentiality and security obligations.
- To service providers, outsourced vendors, research agencies, external consultants, technology providers, cloud / data centre providers, collection agencies, legal counsel, auditors and other third parties engaged by RKPF under written agreements (such as MoUs or service level agreements) that require them to maintain client confidentiality and implement appropriate data security measures, and to process such information only on RKPF’s instructions.
- To banks, payment service providers and other intermediaries for enabling disbursal of funds, repayment collections and other transactions authorised by the Customer.
In any other circumstance, Customer information will be shared only if:
- The Customer has directed RKPF to share it with a third party; or
- There is written permission/consent from the Customer authorising the disclosure.
- Customers are made aware of their privacy rights and responsibilities before they receive their loans or services from RKPF.
Customer responsibilities include: understanding RKPF’s privacy of Customer data clause and their rights; keeping their information updated; storing their loan cards and other important documents in a safe place; informing RKPF promptly if their information has been misused or compromised; and keeping the group’s financial data confidential.
Cross-Border Transfers
If Customer information is transferred outside India (for example, where RKPF uses overseas cloud service providers or technology vendors), RKPF will ensure that such transfers are made in compliance with applicable laws and that the recipient is subject to obligations to protect the information at a level of security comparable to that required under Indian law.

Cookies and Online Tracking

When Customers visit RKPF’s website or use digital platforms, RKPF and its service providers may use cookies and similar technologies to collect certain technical and usage information as described above. These technologies help in:

recognising returning visitors and remembering their preferences;
understanding how the website or platform is used and improving its performance and content; and
enhancing security and preventing fraud.

Customers may be able to control the use of cookies through their browser settings. However, disabling certain types of cookies may affect the functionality or performance of the website or digital platform.

Channel for Complaints

Customers can contact the Customer complaint number (which will available on Welcome Letter) to record any complaint.
Customer can also visit our website https://rkpf.in/ and write to Customersupport@purefinance.in, if not satisfied then Customer can also write to management.rkpf@purefinance.in
If any staff is proven to have breached this Privacy Policy, he or she will be served with penalties (ranging from fines to dismissal) as stated in the HR policy.

Records Management and Physical Data Security

RKPF keeps Customers’ physical files at the head office that received the initial loan application and/or other RKPF offices in a safe manner and only authorised staff are permitted to access the data.
RKPF may engage the services of reputed third-party service providers for record/ data storage/ management purposes under SLAs agreed by RKPF with such third parties in writing. Such SLAs would cover aspects of client data, confidentiality, data security, access control, retention and related compliance requirements
Records may be transferred from branches to other offices of RKPF or to third party service providers for record keeping purposes, subject to appropriate safeguards.
The database of Customers who do not have any current loan outstanding with RKPF is properly archived and stored in the same manner as RKPF stores data/ documents of current Customers, subject to retention periods described below.
All Customer data/ records/ documents/ information shall be maintained by RKPF for such time period as may be required as per applicable laws, including the Prevention of Money Laundering Act and rules thereunder and other regulatory requirements.
Where specific legal retention periods are not prescribed, RKPF will retain personal information for a period that is reasonably necessary for the purposes for which it was collected, for fulfilling contractual and legal obligations, and for establishing or defending legal claims.
Upon expiry of the applicable retention period, personal information will be securely deleted, anonymised or destroyed in accordance with RKPF’s records management and information security policies (for example, through shredding of physical files and secure deletion or anonymisation of electronic records).

Information/IT Security Mechanisms

Each person who accesses the database uses an individual username and password. Users must change their passwords from time to time. Whenever an employee logs into the database, their name, the information they query, and the time when the request is made, are all recorded in a query log
Sensitive information such as account numbers, card details, and PAN numbers is masked or tokenized in systems where full visibility is not required
Access to personal information restricted on a need-to-know basis, with permissions assigned according to job roles and responsibilities
All access to Customer data is logged and monitored; audit logs retained for compliance, regulatory, and investigative purposes
Customer data is stored in secure, access-controlled facilities with physical security measures including CCTV surveillance and security guard.
Data centers are equipped with fire suppression systems, climate control, and redundant power supplies to protect against environmental hazards, wherever applicable.
RKPF endeavours to use industry-appropriate technical and organisational security measures, including encryption, secure configuration, regular backup, and periodic security reviews, to protect personal information against unauthorised access, alteration, disclosure or destruction.
Violations of security policies subject to disciplinary action, ranging from warnings to termination of employment as per organizational and HR policies, without prejudice to any legal remedies available to RKPF.

Regulatory and Legal Compliance

RKPF will ensure that the collection, use, storage, sharing and retention of personal information is carried out in compliance with applicable Indian laws and regulations, including but not limited to:

directions, guidelines and circulars issued by the Reserve Bank of India (RBI) from time to time, including those applicable to NBFCs and, where relevant, to outsourcing of financial services and digital lending;
the Information Technology Act, 2000 and the rules made thereunder, including rules relating to reasonable security practices and procedures and sensitive personal data or information, as applicable;
the Prevention of Money Laundering Act, 2002 and the rules and regulations made thereunder; and
any other applicable laws, regulations and statutory or regulatory directions relating to the protection of personal information and privacy, as may be notified from time to time.

Customer Rights and Choices

Subject to applicable laws and contractual obligations, Customers have the following rights in relation to their personal information held by RKPF:

Right to access and review certain personal information and records, upon reasonable request.
Right to request correction or updating of inaccurate or incomplete personal information.
Right to withdraw consent for processing of personal information where processing is based solely on consent, provided that such withdrawal does not affect processing required under law or for performance of a contract.
Right to object to or restrict certain processing activities, such as direct marketing, where such rights are available under applicable law.
Right to raise concerns or complaints regarding the processing of their personal information, through the grievance mechanisms described in this Policy.

Exercise of these rights may be subject to reasonable limitations, including where requests are manifestly unfounded or excessive, may affect the rights of other individuals, or where retention of certain information is required by law or for legitimate business purposes.

Notice of Change

This policy will be reviewed annually, or earlier in case of any significant technological, business or regulatory changes, by the Board of Directors of RKPF. Any material changes to this Policy will be notified by updating the Policy on RKPF’s official website and / or by such other means as may be appropriate. The updated Policy will be effective from the date specified therein.

Channel for Complaints and Grievance Redressal

Customers can contact the Customer complaint number (which will be available on the Welcome Letter) to record any complaint, including those relating to privacy and personal information.
Customer can also visit our website https://rkpf.in/ and write to Customersupport@purefinance.in, if not satisfied then Customer can also write to management.rkpf@purefinance.in
If any staff member is proven to have breached this Privacy Policy or related information security policies, he or she will be subject to penalties (ranging from warnings and fines to dismissal) as stated in the HR policy and disciplinary procedures.

For any discrepancies or grievances related specifically to personal information or this Privacy Policy, Customers may contact the designated Grievance Officer / Nodal Officer for data privacy matters, whose name and updated contact details are provided under the Grievance Redressal section on the official website of RKPF and / or in the Customer Welcome Letter.

In order to address any discrepancies or grievances related to the personal information residing with RKPF, the Customer may visit the official website of RKPF for details of the escalation matrix and contact details of the designated officers.

Privacy Policy