PRIVACY AND SECURITY POLICY

1. INTRODUCTION:
Sparky Bizconnect Private Limited (hereinafter referred to as “Loan Cluster/ we/ our”) acknowledges the expectations of its customers (hereinafter referred to as “customer/ you/ your”) regarding privacy, confidentiality and security of personal information that resides with the Loan Cluster. Keeping personal information of customers secure and preventing any misuse thereof, is therefore, a top priority of Loan Cluster.

We state that Loan Cluster is strongly committed to protect the privacy of its customers and has taken all necessary and reasonable measures in line with the best industry practice to protect the confidentiality of your personal information and its transmission through our website.

This Privacy & Security Policy (hereinafter referred to as “Policy”) therefore, explains how we protect your personal information provided to us on our website i.e. www.loancluster.com (hereinafter referred to as “Website”) and how we use that information in connection with the service offered through the Website (hereinafter called as "Service").

2. PERSONAL INFORMATION:
Personal Information (“PI”) means any information/ documents/ details that relates to a natural person, which either directly or indirectly in combination with other information available with Loan Cluster, can identify such person.

3. APPLICABILITY:
(i) This Policy applies to the PI such as details pertaining to your name, parentage, marital status, nationality, state/city of residence, residential address, e-mail address, date of birth, gender, contact number/mobile number, recent photograph, signature image, income proof, PAN and such other Know Your Customer (KYC) documents like address proof, identity proof, officially valid documents/details (OVDs) accepted for concluding a financial transaction, which may be shared by you and when you avail any products and/or service through usage of the Website and to which Loan Cluster may become privy to.

(ii) By visiting and/or using our Website, you agree to this Policy. Further, this policy applies to all current and former visitors to the Website. It is strongly recommended for you to return to this page periodically to review the most current version of the Policy.

(iii) Loan Cluster reserves the right at any time, at its sole discretion, to change or otherwise modify the Policy without prior notice, and your continued access or use of this Website signifies your acceptance of the updated or modified Policy.

4. EXPRESS CONSENT:
(i) You while providing your details over the Website, including but not limited to PI as mentioned hereinabove, expressly consent to Loan Cluster (including its marketing channels and business partners) to contact you through SMS, call and/ or e-mail and to follow up calls in relation to the services provided through the Website, for imparting product knowledge, offering promotional offers running on Website & various other offers offered by its business partners.

(ii) Loan Cluster reserves the right (and you expressly authorize Loan Cluster) to share or disclose your PI when Loan Cluster determines, in its sole discretion, that the disclosure of such information is necessary or appropriate under the law for the time being in force.

5. PURPOSE AND USAGE:
(i) Loan Cluster will not sell or rent your PI to anyone, for any reason, at any time. However, we will be sharing your PI with our affiliates and business partners including CICs, where we feel that you will be assisted better for the purpose of underwriting and approval of your loan or any other financial product transaction/related transaction. We assure that Loan Cluster will always seek your consent to process certain types of information where it is legally required to do so. Loan Cluster uses the PI collected to manage its business and offer you an enhanced, personalized online experience on its Website. By registering on the Website, you authorize Loan Cluster to send SMS and e-mail alerts to you for its service requirements, including sending promotional e-mails and SMSs. Further, it enables Loan Cluster to:

1. send you any administrative notices, offer alerts and other communications relevant to your use of the Service;
2. display tailored product offers to you and enable you to apply for certain products and services for which you have chosen to apply;
3. carry market research, project planning, troubleshooting issues, detecting and protecting against error, fraud or other criminal activity;
4. improve our Services and manage our customer relationships better;
5. enforce Loan Cluster General Terms of Use;
6. comply with all applicable laws and regulations.

6. DISCLOSURE / SHARING:
(i) Loan Cluster does not disclose PI of a customer except as directed by law or as per mandate received from the customer / applicant. Upon your written request Loan Cluster will provide you with information on whether we hold any of your PI. No specific information about customer accounts or other personally identifiable data is shared with third parties unless any one of the following conditions is met:

1. To help complete a transaction initiated by you;
2. To perform support services through a third-party service provider, provided it conforms to the Privacy Policy of the Loan Cluster and your prior consent to do so is obtained;
3. You have specifically authorized it;
4. Where the disclosure is necessary for compliance of a legal obligation or as required by law, such as to comply with a subpoena, or similar legal process;
5. When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;

7. WE KEEP YOUR DATA SECURE:
(i) We follow generally accepted standards to protect the PI submitted to us, both during transmission and once we receive it. Since no method of transmission over the Internet, or method of electronic storage, is 100% secure, therefore, we cannot guarantee its absolute security.

8. ALL PRIVATE INFORMATION IS ENCRYPTED AND COMMUNICATED SECURELY:
All communications between your computer/mobile and our Website that contain any PI are encrypted. This enables client and server applications to communicate in a way that is designed to prevent eavesdropping, tampering and message forgery.

9. CONTACT US WITH ANY QUESTIONS OR CONCERNS (GRIEVANCE REDRESSAL):
If you have grievance or complaint, questions, comments, concerns or feedback in relation to the processing of information or regarding this Privacy and Security Policy or any other privacy or security concern, send an e-mail to loancluster@gmail.com.