Turno will only be using the information for providing the Services to you.
IF YOU DO NOT AGREE TO THIS POLICY OR ANY PART THEREOF, PLEASE DO NOT USE/ ACCESS/ DOWNLOAD/ INSTALL THE PLATFORM OR ANY PART THEREOF.
Information collected by Platform for facilitation of Loans being disbursed by the financial lending partners whose details are available on the Website and the Application and who are registered with the Reserve Bank of India (“Lending Partners”).
Information collected by Platform while registering a User on the Platform or while providing Value Added Services (i.e. all services other than facilitation of loans).
In order to facilitate the lending and non-lending services, Turno will be required to access, collect and share Personal Information with its lending partners that may be banks or NBFCs registered with the Reserve Bank of India or any other third-party providing value added services in partnership with Turno. In such cases, Turno will share the information securely and ensure that all personal information recipients comply with confidentiality, fidelity and secrecy obligations and sign covenants in this regard. Turno may make information available to third parties that are financial and non-financial companies, government agencies, courts, legal investigators, and other non-affiliated third parties as requested by You or Your authorized representative, or otherwise when required or permitted by law.
The data points we collect from You for both lending and non-lending services include, inter alia, your full name, email id, PAN, GST Network user id & password, address, mobile number, postal code.
We additionally collect certain device information provided herein for our lending and non-lending services. Information which the Application collects, and its usage, depends on how you manage your privacy controls on your device.
When you install the Application, we store the information we collect with unique identifiers tied to the device you are using. We collect information from the device when you download and install the Application and explicitly seek permissions from You to get the required information from the device. Additionally, we also collect your Log information (via the domain server through which the User accesses the App Search queries, IP address, crashes, date etc for the purpose of improvising the Application functionality. In addition to the above, we also track and collect the data related to the performance of the Application and other diagnostic data for identifying and resolving any technical glitches that may be identified from such data and also for improving the overall functionality of the Application.
We collect information about your device to provide automatic updates and additional security so that your account is not used in other people’s devices. In addition, the information provides us valuable feedback on your identity as a device holder as well as your device behavior, thereby allowing us to improve our products interaction, quality of services and provide an enhanced customized user experience to you. We further collect other identifiable information such as your transactions history on the Platform when you set up a free account with us.
We will collect your device location and request camera access for facilitating lending services as well as providing any non-lending services only in accordance with applicable laws.
How we use this information: We shall collect your device location information for verifying your address, for the KYC and onboarding process for the Services. We may request camera access to scan and capture the required KYC documents as per the instructions of our Lending Partners in accordance with applicable laws. We shall transfer such information to our Lending Partners and shall not store any such data.
For making the Services available to you, we may collect credit information by obtaining specific authorisations from you (if required under applicable laws), from certain third parties such as credit bureaus or credit rating companies as your ‘authorized representative’ from time to time in accordance with applicable laws during the loan journey as may be requested by our Lending Partners.
In order to facilitate credit products to you, we may receive certain information pertaining to document verification, repayment status etc from certain third parties including NSDL, payment gateway providers.
We may further collect your GST details from Official GSTIN API stack or other relevant websites using the GST Network user id and password details or OTP as provided by you.
We may further collect your bank account numbers or UPI payment information on behalf of our lending partners to facilitate collection and repayment of loan payments.
We shall only collect this information on a need basis strictly for the purpose of providing you with the Services. The information collected from such third parties are not retained by us. We collect this information as part of our outsourcing obligations to our Lending Partners and is directly transferred to the Lending Partners upon collection.
In due course of using our Services, you are required to submit data to enable our Services. We use this data to create your profile and provide you with the best available services. Mentioned below is some of the data we collect from you:
This data helps us create your profiles, complete mandatory KYC as per the requirements of our Lending Partners who offer you the Services, unlock and approve loans and provide you with customized support in case of issues. Please note that we do not store any data provided by you except for the basic information such as name, address, contact details etc.
Wherever possible, we indicate the mandatory and the optional fields. You always have the option to not provide any information by choosing not to use a particular service or feature on the Platform. While you can browse some sections of our Platform without being a registered member as mentioned above, certain activities (such as availing of loans from the third-party lenders on the Platform) require registration and for you to provide the above details. We under no circumstances and at no point take any biometric data from you for any of our services or operations. In case, if any of our representatives ask for the same from you, we request you to kindly refrain from doing the same and address this concern to our Grievance Officer (the details of the same have been provided below).
For the provision of lending Services, we shall only store basic personal information such as name, address, contact information which are required to be stored for carrying out our non-lending services. We ensure that every data or information that we collect from you is stored in servers located in India and the same is compliance with all the statutory/regulatory obligations. For other personal information collected as part of our outsourcing services being provided to our Lending Partners, we shall collect such information upon the instructions of the Lending Partners and thereafter transfer the same to the Lending Partners upon the completion of the preliminary onboarding.
We automatically track certain information about you based upon your behavior on our Platform. We use this information to do internal research on our users’ demographics, interests, and behavior to better understand, protect and serve our users and improve our services. This information is compiled and analyzed on an aggregated basis.
If you choose to make a purchase through the Platform, we collect information about your buying behavior. We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law. If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Website, we collect such information into a file specific to you.
We shall use the information collected from you for facilitating the lending and non-lending Services for the following purposes as detailed below. We understand the importance of your information and ensure that it is used for the following intended purposes only.
We will use and retain only such basic personal information such as your name, contact information, address details and such other information which are necessary for the provision of Services and for such periods as necessary to provide You the Services on the Platform, to comply with our legal obligations, to resolve disputes, and enforce our agreements.
We will share Your information only with our third parties including our regulated financial partners, vendors etc for facilitation of Services on the Platform.
We will share the information only in such manner as described below:
Any disclosure to third parties is subject to the following:
List of entities with whom your information is shared can be assessed at https://www.turno.club/our-lending-partners
We at Turno promise to protect your personal data from unauthorized access, misuse, and disclosure using the right security measures based on the type of data and how we are processing the same. We retain information about you to provide a seamless experience, to contact you in case of support required and about your account, to detect, mitigate, prevent, and investigate fraudulent or illegal activities during the course of the Services. We retain your data for as long as necessary to provide you with our services. We may also retain and use your basic personal information inter alia as name, contact number, transactional details and address details as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements which shall always be in accordance with applicable laws. Subject to this section, we may delete your data upon reasonable written request for the same at any stage. However, you may not be able to use our services after deletion.
The App has a link to registered third party SDKs, Application Programming Interface (API) integrations, redirections which collects data on our behalf and data is stored to a secured server. We ensure that our third-party service provider takes extensive security measures in order to protect your personal information against loss, misuse or alteration of the data as required under the applicable laws.
Our third-party service provider employs separation of environments and segregation of duties and have strict role-based access control on a documented, authorized, need-to-use basis. The stored data is protected and stored by application-level encryption. They enforce key management services to limit access to data.
Furthermore, our registered third-party service provider provides hosting security – they use industry-leading anti-virus, anti-malware, intrusion prevention systems, intrusion detection systems, file integrity monitoring, and application control solutions.
We don't allow unauthorized access to your nonpublic personal contacts or financial transaction with any third party in relation to Lending Services other than our Lending Partners. However, for Non-Lending Services (Value Added Services i. e. Expense Tracker), we may allow third parties to access your financial transaction to your explicit consent.
Our Platform links to other websites that may collect information about you. We are not responsible for the privacy practices or the content of those linked websites. With this Policy we’re only addressing the disclosure and use of data collected by Us. Their data collection practices, and their policies might be different from this Policy and We do not have control over any of their policies neither do we have any liability in this regard.
The Platform intends to protect your information and to maintain its accuracy as confirmed by you. We implement reasonable physical, administrative and technical safeguards to help us protect your information from unauthorized access, use and disclosure. For example, we encrypt all information when we transmit over the internet. We also require that our registered third-party service providers protect such information from unauthorized access, use and disclosure.
Our Platform has stringent security measures in place to protect the loss, misuse and alteration of information under control. We endeavor to safeguard and ensure the security of the information provided by you. We use Secure Sockets Layers (SSL) based encryption, for the transmission of the information, which is currently the required level of encryption in India as per applicable law.
We blend security at multiple steps within our products with the state-of-the-art technology to ensure our systems maintain strong security measures and the overall data and privacy security design allow us to defend our systems ranging from low hanging issue up to sophisticated attacks.
We aim to protect from unauthorized access, alteration, disclosure or destruction of information we hold, including:
We ensure that the Aadhaar number is not disclosed in any manner.
Data protection laws vary among countries, with some providing more protection than others. We also comply with certain legal frameworks relating to the transfer of data as mentioned and required under the Information Technology Act, 2000, rules and the amendments made thereunder.
When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.
Modifying or rectifying your information: In the event that any Personal Information provided by You is inaccurate, incomplete or outdated then You shall have the right to provide Us with the accurate, complete and up to date data and have Us rectify such data at Our end immediately. We urge You to ensure that You always provide Us with accurate and correct information/data to ensure Your use of Our Services is uninterrupted. In case of modification of Personal Information, Users will be required to furnish supporting documents relating to change in Personal Information for the purpose of verification by the Company.
Your Privacy Controls: You have certain choices regarding the information we collect and how it is used:
Withdrawal/Denial of consent: You acknowledge that the Platform has duly collected the information with your consent and you have the option to not provide such information, or deny consent for use of specific information or revoke the consent already given. However, any withdrawal of such personal information will not be permitted in case any Service availed by You is active. Where a consent has been withdrawn the Platform does not guarantee or be liable for providing such Service. You shall have the following rights pertaining to your information collected by us.
You have a right to report a security incident to the GRO (detailed mentioned hereinbelow). You are entitled shall be entitled to prevent unauthorised such usage of your information by our personnel/agents by informing us, within 10 days of being informed of the proposed use, that you do not wish to disclose such information. You can also exercise the right at any time by contacting us at firstname.lastname@example.org.
Notwithstanding anything to the contrary stated above, the following are specific scenarios listed below which may have consequences to your withdrawal of consent:
You may make a request for deleting any information from the Platform at any stage upon making a request to Us in the following manner:
In accordance with Information Technology Act 2000 and rules made there under, the name and contact details of the Grievance Officer are provided below for your reference: