PRIVACY POLICY
Scope of Service:
This Privacy Policy lays down the policies and guidelines governing the protection of your Personal Information (as defined below) including Sensitive Personal Data collected, processed, and stored by Invest Gold General Finance Pvt Ltd (IGGFL), for providing effective products and services to our users. The Company owns and operates Mobile Application “Invest bank” and website www.investgoldfinance.com (App and Website are hereinafter together referred to as the "Platform").
Personal Information:
Personal Information means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person. Non-Personal Information means any information that does not result in the identification of an Individual. Non-Personal information includes but not limited to your IP address, cookies and third party's cookies
Sensitive Personal Data:
Sensitive Personal data refers to the information of a person that is more sensitive in nature including but not limited to passwords, financial information such as bank account, credit card, debit card or other payment details, physical, physiological, and mental health condition, sexual orientation, Aadhaar details, medical records and history and biometric information (including but not limited to Finger prints, Eye retina and irises, Voice patterns, Facial patterns, Hand measurement, DNA) The personal data/information which is freely available to us or accessible in public domain or information furnished under the Right to Information Act, 2005 or any other law for the time being in force or information furnished under the directives of regulatory/statutory body shall not be regarded as Sensitive Personal Data for the purpose of this policy.
Our Commitment:
We are committed to protect the privacy of personal/non-personal information shared by you either through online on our website or digital platform or offline and/or any personal information which may be collected by us, affiliated entities, subsidiaries, our WhatsApp and social media pages, our representatives or agents/agencies or our server from the User’s browser.
Collection of Personal Information:
The personal information pertaining to your identity and demographics or any non-personal information shall be collected by us for enabling us to provide following services:• Lending Services and Non-Lending Services- Information will be collected by IGGFL Branches and offices while providing lending and non-lending services.
• Digital Lending and Non-Lending Services- Information will be collected by Invest Gold Finance (Platform) for facilitation of lending and non-lending services offered by the IGGFL.
What type of information Invest Gold Finance (Platform) collects?
When you visit our website/platform or mobile app, we collect the following types of information from you:• Contact Information: Your name, address, phone no, email Id, date of birth, gender, and other similar information.
• Financial Information: UPI VPAs, part of card details, bank account numbers, bank statements, bank IFSC codes, wallet balance, your billers bank account number and IFSC and information related to your all successful and failed payment attempts, nominee details and their contact number. Reference details and their contact numbers; Income Tax details, GST details, TDS details etc
• Location Information: Full addresses, latitude and longitude of locations shared by you, state, city, pin codes etc.
• KYC Information: Your photo, PAN no, PAN copy, Aadhar No, address proof ID no., picture, and address proof copy.
• Type of Address Proofs: Driving license, voter ID, passport, Aadhar information.
• Demographic and related information: Income, location, age, gender, preference, occupation and interests.
• OTP sent by Invest Gold Finance or our platform-Device details such as devise identifier, internet bandwidth, mobile device model, browser plug-ins, and cookies or similar technologies that may identify your browser/Invest Gold Finance Application and plug-ins, and time spent, IP address and location.
• Other Information relevant to capture feedback, transaction experience and to push customised marketing offers.
• Contact us- if you email us through the "Contact Us" section on the website, we ask you for information such as your name and email address so we can respond to your questions and comments. You may choose to provide additional information as well.
Usage of your Personal Information:
Any of the information we collect from you may be used in one of the following ways:• To personalize your experience with us by presenting products & offers tailored/ suitable to you - Your information helps us to respond to your individual needs in a better way.
• To verify your identity as per applicable laws.
• To improve your experience with our website/app/platform - We continually strive to improve our website/app/platform offerings based on the information and feedback we receive from you
• To improve customer service - Your information helps us to respond to your service requests and support needs more effectively.
• To process your transactions easily
• To administer a contest, promotion, survey, or other site feature – We shall reach out to you when we are conducting any contests or surveys. You may opt out if you do not wish to be included.
• To send periodic emails, SMSs & WhatsApp messages & occasionally in-bound phone calls - The email address or mobile number that you provide may be used to send you information, respond to inquiries, and/or other requests or questions.
• To keep you informed about our new products or services unless you unsubscribe to our emails.
• To carry out research and analysis to study customer use and experience on an anonymous or personalized basis.
• Other usages that you may consent to including WhatsApp for Business.
• For Collection & related services.
Processing of Aadhaar details:
IGGFL will collect and process the Aadhaar card as per Aadhar (Targeted Delivery of Financial and Other Subsidies Benefits and Services) Act 2016 and Aadhaar and Other Laws (Amendment) Act, 2019. Currently IGGFL is not a live Authentication User Agency (AUA) or e-KYC User Agency User Agencies (KUA). However, IGGFL is allowed to do offline KYC (which is the method by which the QR code in the Aadhaar card is scanned by the scanning device and the static data is populated in the system), but not doing Offline KYC at present.IGGFL will collect copy of Aadhaar card of its customers as one of the KYC documents. IGGFL have a clear and stringent process in place defined by its Operations and Internal Audit team to secure the personal information mentioned in such copy of Aadhaar card. IGGFL Branch staff have been instructed to keep the copy of Aadhaar card safely under Lock and Key. IGGFL Branch staff is also instructed to mask/black out the first 8 digits of the Aadhaar number and make visible the last 4 digits for future business reference. The process is verified on a regular basis by the Internal Auditors as part of their Audit at IGGFL Branch. Additionally, IGGFL have also taken all precautionary steps to prevent the misuse of your Aadhaar details.
Your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the purchased product or service requested. IGGFL may however, share personal information to our group companies, for providing better services to you, if you expressly consent to do so.
Information we share:
• Group Companies, authorized agents or trusted third party service providers who assist us in operating our website, conducting our business, or servicing you shall have access to your information on need-to-know basis and are restricted from using the same for any other reason. The third-party service provider is obligated not to disclose or use the information for any other purpose.• To share information with relevant authorities, including RBI/Income Tax and other government authorities, credit reference agencies, fraud prevention agencies and India and overseas regulators and authorities.
Consent:
You hereby expressly consent to provide the information that may be required for providing the services as mentioned above. You acknowledge that we shall collect the information as per this privacy policy to provide/facilitate lending and non-lending services by us or by partnering with various financial lenders, third parties, service providers etc.IT IS ADVISED THAT YOU READ, UNDERSTAND, ACKNOWLEDGE AND UNCONDITIONALLY AGREE TO BE BOUND BY THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS POLICY OR ANY PART THEREOF, PLEASE DO NOT SE/ACCESS/DOWNLOAD/INSTALL THE PLATFORM OR ANY PART THEREOF.
Acknowledgment of the User
You agree that IGGFL shall have every right to use the Information to initiate the dialogue with you with respect to various products, services and other allied and necessary requirements as may be deemed necessary by IGGFL.You acknowledge that you are completely aware about the potential risk of data/privacy breach and hereby confirms that you shall be solely liable for any unauthorized disclosure/breach personal/sensitive personal information, etc and any direct/indirect losses suffered. Hence, you shall exercise utmost caution to ensure that your information is NOT shared/stored/made accessible through:
(i) Any physical means with or without your knowledge (disclosure to any person/third party; etc) or through any electronic means, by exercising the following precautions/safety measures:
• You shall always check if “https” appears in any website’s address bar before making any online transaction, to ensure that the webpage is encrypted.
• You shall avoid using third party extensions, plug-ins, or add-ons on the/your web browser, as it may result in the risk of tracking or stealing of personal details.
• You shall always type the information and not use the auto-fill option on web browser to prevent the risk of storage of my personal/sensitive personal information.
• You shall NOT access unauthorized/suspicious websites, suspicious online platforms, downloading applications from unreliable sources.
• You shall ensure to disable cookies before accessing any domain/website, to ensure that your personal information is not tracked by any third party, unless otherwise consciously permitted by you by accepting the same, for which, you are solely responsible for the consequences thereof.
• You shall NOT respond to any generic emails from an unknown/unidentified source.
• You shall check the Privacy Policy of the website/application to know the type of information that may be collected from you and the manner in which it may be processed by the website/application before accepting/proceeding/transaction on any website/application.
• You shall always verify and install authentic web/mobile applications from reliable source on User’s computer/laptop/tab/ipad/smart phone or any other electronic device.
• Apart from the communication sent by us through trusted weblinks or short URLs (Uniform Resource Locator) leading to hosted webpage / mobile application (app) of Invest Gold Finance, you shall NOT access any unidentified weblinks, bitly link or any other electronic links shared over electronic platform (such as email, sms, social media, WhatsApp, websites).
Protection of Personal Information:
We implement a variety of security measures to protect your personal information from unauthorized access or disclosure. Further our employees who have limited access to your personal information are bound by Non-Disclosure and Confidentiality Policies. You will appreciate the fact that no method of transmission, whether in physical form or over the internet, or method of electronic storage is 100% secure and maybe subjected to unintentional risks, due to reasons beyond our control.
Disclosure of Personal Information:
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties comply with applicable laws and agree to keep this information confidential.1. Your Personal Information may be transferred to outside parties under following circumstances: We may share the personal information with other Group Companies or other trusted entities or agents or representative who act on our behalf to call and communicate with you about products offerings through Telephone/Mobile/SMS/Email/Whatsapp
2. We may share the personal information with the statutory and/or regulatory authorities, government institutions where required for compliance with legal requirement.
3. We may use the personal information to respond to court orders or legal process to establish or exercise our legal rights or defend against legal claims
4. We may share the personal information in order to investigate, prevent, or take action against any illegal activities, suspected fraud, or as otherwise required by law.
5. We may share the personal information in order to protect or enforce our rights and claims.
Retention of Personal Information:
We will retain your Personal information for as long as necessary to provide you the services, or for complying with our statutory/regulatory obligations, resolving disputes, defending the claims, and enforcing our policies.
Changes to the Privacy Policy:
This Privacy Policy shall be amended from time to time to comply with our business requirements and applicable laws. The amendments made to this Privacy Policy shall be updated on this website. You may visit this website to view the changes in policy. These changes are effective immediately after they are posted on our website. Please regularly check this Privacy Policy to ensure you are aware of the latest updates.
Modification and Rectification of Information:
If the personal information provided by you is inaccurate, incomplete or outdated, in that case you can reach to us at info@investgoldfinance.com or cpc@investgoldfinance.com for rectifying the same.
Contact us:
In case if you may want to share your concern, we welcome you to easily reach out to us through multiple contact options displayed on our website www. investgoldfinance.comGRIEVANCE REDRESSAL POLICY FOR STAKEHOLDERS
Stakeholders are individuals or groups concerned or interested with or impacted by the activities of the businesses and vice versa, now or in the future. Typically, stakeholders of a business include, but are not limited to, its investors, shareholders, employees, and workers (and their families), customers, communities, business partners, regulators. Invest Gold Finance recognizes employees, customers, investors as key stakeholders.
A complaint is an expression of dissatisfaction with a product or service, either orally or in writing, from internal and external stakeholders. Complainants may have genuine cause, although some may be result of misunderstanding or an unreasonable expectation about a product or service.
Complaints are also used as a feedback instrument for bringing about improvement in services. The Grievance Redressal Policy broadly strives to ensure that:
• The stakeholders have full right to register his/ her complaint if he/ she is not satisfied with the services provided by Invest Gold Finance.
• The stakeholder may give complaint in writing or orally - in person / over telephone etc.
• Stakeholders will be fully informed of avenues to escalate their grievances within the organization and their rights to alternative remedies, in case of dissatisfaction with the response of the company to their complaints.
• The organization shall treat all complaints efficiently in an unbiased manner as handling it otherwise will damage the company’s reputation and business.
• To make the company’s redressal mechanism more meaningful and effective, a structure is designed, which would ensure that the redressal sought is just and fair and is permissible within the given framework of rules and regulations.
• The policy document will be made available on the company’s website.
Grievances logged under this policy will be addressed in a timely manner and investigation outcomes will be shared with relevant parties transparently.
Objective
The policy on Stakeholder Grievance Redressal aims to reiterate the company’s core values by laying down a structured system which would ensure availability of multiple channels within the company for stakeholder grievance redressal. The policy would also ensure that redressal would be fair, consistent and in accordance with the existing rules and regulations.Stakeholder Engagement Mechanisms
| Stakeholder Group | Engagement Mechanisms |
|---|---|
| Customers | Customer feedback calls Personal Interaction |
| Employees | Trainings Personal Interactions Departmental Meetings |
| Investors And Lenders | Earnings calls Annual Reports Investor Meets |
Frequency of stakeholder engagement mechanisms will be decided by the committee/board of directors from time to time.
Stakeholders point of contact:
| Stakeholder Group | Point of Contact for Grievances | Contact Details |
|---|---|---|
| Customers | Level 1 : Branch Manager | Concerned Branch |
| Level 2 : Nodal Officer | E-mail: customercare@investgoldfinance.com Phone: +91- 9207100053 |
|
| Level 3: Chief Compliance Officer | E-mail: ceo@investgoldfinance.com Phone: +91- 7510393939 |
|
| Level 4 : RBI Ombudsman | Centralised Receipt and Processing Centre Reserve Bank of India, 4th Floor, Sector 17, Chandigarh – 160017 Toll Free no. - 14448 (9:30 am to 5:15 pm) Website : https://cms.rbi.org.in | |
| Employees | Level 1 : HR Manager | E-mail: mail@investgoldfinance.com Phone: +91- 7558821000 |
| Level 2: Chief Compliance Officer | E-mail: ceo@investgoldfinance.com Phone: +91- 7510393939 |
|
| Investors And Lenders | Level 1: Chief Compliance Officer | E-mail: ceo@investgoldfinance.com Phone: +91- 7510393939 |
Grievance Redressal Timeline
| Activity | Timeline |
|---|---|
| Acknowledgement of Grievance | 3 Days |
| Screening Grievance | 3 Days |
| Investigating Grievance | 4 Days |
| Escalation of Grievance | 4 Days |
| Action on the grievance | 4 Days |
| Follow up and closure | 3 Days |
Salient Features of the Policy
• The company’s Grievance redressal cell shall be the designated point for receipt of complaints.• Complaints received at all branches / offices shall be acknowledged and accepted.
• Complaints shall be monitored and marked as closed only after resolving / replying to the stakeholder grievance.
• Complaints received from Regulators will be resolved by Principal Nodal Officer at Head Office accordingly. The timelines as mandated by the respective regulator will be adhered to, as far as possible.
• The Grievance Redressal Policy will be accessible to all to ensure that information of lodging and resolving complaints is readily available to all. This policy will be available on the company’s website as well as at Branches / Offices and shall be made available to stakeholders free of charge upon request.
• There will be no charge for lodging a complaint.
• Details of complainant and/ or complaint will be shared with other organizations/ regulatory authorities only if in accordance with the laws of the country and the stakeholder will be kept apprised about the same. Sharing of information otherwise will be done only with a written consent of the stakeholder except in the case of regulatory/ statutory provisions to disclose the same in terms of the laws in force. The same will be done only in circumstances where the input of an external agency /organization is necessary for resolving the complaint.
Grievance reporting mechanism
The grievance can be reported in one of the following ways –
In-person:
• Complaints / disputes arise on the decisions of officials below the Branch Manager will be heard and disposed of by the Branch Manager.
• Customer Grievance Cell address of RO/ HO and escalation matrix will be exhibited on the branch notice board.
Letter / Email:
• Stakeholders may register their Complaints / Feedback / Suggestions in writing addressed to the Branch, Head Office or any executive of the company or their designated email ids.
Complaints can be sent to : Grievance Redressal Cell, First Floor, Invest Complex, Urakam – 680562 / mail@investgoldfinance.com
Over Telephone/ WhatsApp:
Stakeholders may register their complaints over phone in any of the company’s registered landline numbers / mobile number of Chief Compliance Officer.
To facilitate faster and complete resolution of complaints, a complaint letter /email should contain:
• Complainant’s name, address, and contact details (e-mail id, phone / mobile numbers etc.)
• Relationship information of stakeholders with the organization.
• Details of previous complaint / request lodged, if any.
• Details and nature of the complaint.
• Name of the company and branch at which the complainant had encountered the cause of action leading to the complaint.
• Copies of supporting documents, wherever applicable.
Acknowledgement of Grievances
A grievance once received will be acknowledged by the grievance owner, within three working days of the grievance being submitted. The mode of communication shall be in written format, over telephone, e- mail or verbal.
Resolution of Grievances
If a complaint is with respect to a particular branch, stakeholders may contact the Branch Manager (BM) directly or by phone, e-mail, or any other means, to get their grievance redressed. BM shall strive to resolve the complaint within the next working day of receiving the grievance at the branch level itself.
If the grievance is not redressed within the next working day at the branch level itself, a complaint may be lodged to higher authorities. To ensure an effective complaint redressal mechanism, the company has put in place the following complaint redressal system for all channel complaints.
1. Stakeholders may lodge their grievances through any of the above mechanisms and it will be directed to the appropriate business/control unit concerned for resolution.
2. Grievances will be handled by the official designated for the same in the business/ control unit concerned. On exceeding the stipulated TAT it can be escalated to head of business/ control unit concerned. 15 working days will be allotted at this level for resolution post which the complaint can be escalated to the Nodal Officer assigned with complaint resolution. Branches, Regional
Offices and HO shall enter the particulars of complaints received and the details of action taken. The details of action taken regarding complaints lodged through the company’s website shall also be noted.
3. All complaints resolutions will be closed within a maximum period of 30 days.
Reference to Chief Compliance Officer :
Any complaint that is to be wholly / partly rejected will be forwarded to the company’s Chief Compliance Officer. The CCO shall examine the wholly/partly rejected complaints within a maximum period of 7 days and convey his/her decision. CCO’s decision shall be informed to the complainant within a maximum duration of 30 days. The decision of the CCO shall be binding on Invest Gold Finance, except in cases where it has obtained approval for disagreeing with the CCO’s decision as stated in hereunder.1. In case the CCO upholds the decision of Invest Gold Finance to reject the complaint wholly/partly, the reply to the customer shall contain the fact that the complaint has been examined by the CCO and, for the reasons stated in the reply, the decision of Invest Gold Finance has been upheld.
2. In case of complaints that are fully or partly rejected even after examination by the CCO, the company shall advise the complainant as part of the reply that he/she can approach the RBI Ombudsman for redress, if the complaint falls under the RBI Ombudsman Mechanism.
The Reserve Bank - Integrated Ombudsman Scheme
If a customer does not receive a response from Invest Gold Finance within 30 days from the date of filing of complaint or if he is dissatisfied with the response received from the company the customer can file complaint with RBI Ombudsman ‘s office not later than one year after he has received the reply from Invest Gold Finance.
The different modes of filing complaint are given below:-
• Complaints can continue to be filed online on https://cms.rbi.org.in.
• Complaints can also be sent in physical mode to the ‘Centralised Receipt and Processing
Centre’ set up at Reserve Bank of India, 4th Floor, Sector 17, Chandigarh - 160017 in
the prescribed format.
• Complaint can also be registered at Contact Centre with a toll-free number – 14448 (9:30
am to 5:15 pm) in Hindi ,English and in 8 regional languages.
Roles and Responsibilities
| Role Title | Responsibility |
|---|---|
| Customer Relationship Officers |
•Responsible for handling grievances in respect of branches/ functional units •Primary level of grievance screening to be conducted by nodal officer to check appropriateness |
| Branch Manager/Regional Manager |
•Branch Managers are responsible for investigation of grievances when dispute arises on the decisions of officials below the Branch Manager •Regional Managers are responsible for handling complaints against Branch Managers |
| Nodal Officer |
•Primary point of contact for all communication between respondent and the grieved (grievance raiser) •Responsible for managing the grievance redressal through a structured process. •NO will handle complaints that are not redressed at RO level and complaints escalated to RBI Integrated Ombudsman |
| Chief Compliance Officer |
• Point of contact for all grievances and forwarding to Grievance Committee • Maintains grievance register and monitor any correspondence. • Responsible for documenting interactions with internal / external stakeholders. • Grievance monitoring over time and finding trends or • findings to report to the Committee. |
| HR Manager |
•Point of contact for receiving grievances in person. •May help in developing responses or close out grievances. Report grievance to the Chief Compliance Officer through appropriate for forms |
A Grievance Resolution Panel / committee may be formed consisting of Cross Departmental Team (CDT), with pertinent experience, as required on a case-to-case basis.
The CDT, shall be headed by Corporate Sustainability and CSR / Internal Audit Team, will include representatives drawn from at least three of the following functions:
1. Business & Operations Team
2. IT & Admin Team
3. Accounts & Finance
4. HR
5. Corporate Communications
Escalation & Appeal Options
• Stakeholders will be fully informed of avenues to escalate their grievances within the organization and their rights to alternative remedies, in case of dissatisfaction with the response of the company to their complaints.• The escalation matrix will be exhibited on the branch notice board and website.
Sensitizing Operating Staff on Handling Complaints
Grievance redressal committee members / staff shall be properly trained for handling complaints. We are dealing with people and hence differences of opinion and areas of friction can arise. Imparting soft skills required for handling agitated stakeholders, will be an integral part of the training programs.
Record Keeping & Data Base
The record of complaints would be maintained for a period of ten years from the date of their resolution.
Monitoring
This policy shall be regularly monitored by the Grievance redressal committee/ Board .