PRIVACY POLICY

1.  About

This Privacy Policy explains how 121 Finance Private Limited handles personal information when you visit our website, contact us, apply for finance, use our customer portal or other digital services that link to this Policy, or act for a business that deals with us. It describes how you can contact us about your information. A separate notice or consent shown during a particular service may give more specific details and will apply to that activity.

Who we are and where this Policy applies

121 Finance Private Limited (“121 Finance”, “we”, “us” or “our”) is an RBI registered NBFC Factor.

This Policy applies to individuals, including website visitors, applicants, customers, employees, and other people whose information we handle in connection with our services. Information about a business is covered when it identifies or can be linked to an individual. Services operated by another organisation may have their own privacy notice.

2. Personal information we collect

The information we collect depends on your relationship with us and the service you request. It may include:

  • Identity and contact information, such as name, designation, business name, address, email address, telephone number, date of birth and identity document details.
  • KYC and due diligence information, such as tax and registration identifiers, identity and address evidence, beneficial ownership, authorised signatory details, photographs and verification results.
  • Financial and transaction information, such as bank account and statement information, invoices, purchase orders, payment and repayment details, GST and other tax records, credit information and information needed to assess a proposed facility.
  • Communications and service information, such as enquiries, applications, complaints, correspondence, consent choices and records of instructions or interactions.
  • Digital information, such as login and authentication records, device and browser details, IP address, pages visited, timestamps, cookies and similar identifiers. Camera or microphone information may be used where necessary for video KYC or another feature and with the permission required for that feature.

We may receive information from you or your business, an authorised representative, a buyer or supplier connected to a transaction, service providers, public or official records, and regulated information systems where access is permitted. Access to credit bureau information, Account Aggregator data and other consent based sources will be governed by the specific authorisation presented at the relevant step. Accepting website terms alone is not a substitute for that authorisation.

3. Why we use personal information

We use information as needed to answer enquiries; assess eligibility and applications; verify identity, authority, beneficial ownership and underlying trade transactions; decide whether to provide and administer finance; process payments and collections; prevent fraud and protect our systems; meet legal and regulatory requirements; address complaints; and maintain records and improve our services.

We may also use your contact details for relevant product updates or marketing where permitted. You can ask us to stop promotional communications using the option in the message or the contact details below. Service, security, contractual and regulatory communications may continue while they are needed.

For an application or transaction, we may analyse submitted records and information from permitted sources to assess credit and fraud risk. A product specific notice or document will explain any additional data use that is material to that journey.

4. Consent and your choices

Where consent is required, we will explain the information requested and the purpose at the relevant point of collection. For digital lending journeys covered by RBI directions, we will seek prior, explicit, purpose specific consent for need based collection by a digital lending application and keep the required record of that consent. We will provide the applicable choices to allow or deny specific data access, restrict sharing, withdraw consent and request deletion where those directions require them.

You can contact us to withdraw consent where it is the basis for a particular use. Withdrawal does not affect processing that was lawful before withdrawal or information we must use or retain under applicable law, a regulatory requirement or an existing facility. Some services may no longer be available if information necessary to provide them cannot be used.

A mobile application used for digital lending will not seek access to contacts, call logs or files and media for lending purposes.

Any one time use of a camera, microphone, location or similar device function for onboarding or KYC will be limited to the necessary purpose and subject to the required permission.

5. Who we share information with

We disclose information only when needed for the purposes described above and subject to applicable law and permissions. Recipients may include:

  • Regulators, government authorities, courts and law enforcement agencies where disclosure is required or permitted by law.
  • Credit information companies, KYC registries, Account Aggregator participants, banks, payment systems and other authorised data sources or recipients where the relevant legal basis and consent requirements are met.
  • Technology, hosting, communications, verification, video KYC, collections, audit and professional service providers that support our work under appropriate contractual and security controls.
  • Lending service providers or digital platforms involved in a journey you choose, subject to the applicable arrangements, disclosures and borrower permissions.
  • Relevant parties to a financing transaction, such as a buyer, supplier or anchor, to the extent needed to verify or administer that transaction.

Where a third party may collect personal information through a digital lending application, the third party and its role must be disclosed in the applicable journey and in the final public version of this Policy. We do not treat an external website as our own service merely because we link to it; its operator may publish a separate privacy policy.

6. Storage retention and deletion

We keep personal information only while it is needed for the stated purpose and any applicable contractual, accounting, tax, regulatory, record keeping, fraud prevention or legal claim requirements.

Where the RBI Digital Lending Directions apply, customer data is stored on servers in India in accordance with those directions. Any permitted processing outside India, if used, must meet the applicable return and deletion conditions and other legal requirements.

7. Security and incidents

We use administrative, technical and physical safeguards appropriate to the information and the services involved, including controlled access, authentication, monitoring, secure transfer and vendor oversight. We review security measures and handle suspected incidents under our internal procedures and applicable reporting requirements. No internet transmission or storage system can be guaranteed to be entirely free of risk.

8. Website cookies and similar technologies

Our website may use cookies and similar technologies for site operation, security, remembering preferences and measuring use. Analytics or marketing technologies, if enabled, may receive device and usage information. Your browser and any available website preference control can help you manage optional cookies; disabling some technologies may affect a feature.

9. Your requests and complaints

You may contact us to ask what personal information we hold about you, request a correction or update, ask for deletion where permitted, raise a concern about its use, or withdraw a consent that you previously gave. We may need to verify your identity or authority before acting and may need to retain records required by law or for an existing facility. We will respond according to the law and regulatory directions in force when we receive your request.

Send a privacy request to info@121finance.com or write to 121 Finance Private Limited at the registered office stated above. For customer service, our published contact number is +91 9314 121 121. If the concern relates to a financing service, you can also use the grievance process published at https://121finance.com/grievance-redressal-2/.

As provisions of the Digital Personal Data Protection Act 2023 and its rules come into force, we will apply the rights and complaint processes that are then in effect and update this Policy and any collection notice where necessary.

10. Information about other people

If you provide us with personal information about an employee, director, guarantor, buyer, supplier or another person, please ensure that you have authority to share it and that any notice or permission required for that disclosure has been provided or obtained. We may provide a separate notice directly to the person when appropriate.

11. Changes to this Policy

We may update this Policy when our practices, services or applicable requirements change. The current version and effective date will be posted on our website. If a change materially affects how we use information already collected, we will provide any further notice or obtain any fresh consent required by applicable law.

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