TRANSUNION CIBIL PRIVACY POLICY

The purpose of this policy is to maintain the privacy of and protect the personal information of vendors, (and/or any of their employees), partners, members, end-users of TransUnion CIBIL Limited (“we”, “us”, “our”, “TransUnion CIBIL”) or any other individual whose personal information we receive and to ensure compliance with all laws applicable to us.

The contents of this privacy policy (“Privacy Policy”) along with the general terms and conditions (“General TNC”) available at http://www.transunioncibil.com/terms-and-conditions are applicable to all hyperlinks under http://www.transunioncibil.com and http://www.cibil.com and/or any other channels such as mobile application (“Websites”)

You hereby acknowledge of having read and accepted the terms of the Privacy Policy by use of this Website and/or otherwise by virtue of expressly consenting to provide us with your personal information. The capitalized terms used herein and not defined shall have the meaning set out in the General TNC.

TransUnion CIBIL’s Privacy Statement

This Privacy Policy describes our policies and practices on the collection, use, disclosure, storage and security of information on the Websites.

Our Privacy Policy explains:

  • What information we collect, how and why / the purpose for which we collect it
  • How we use that information
  • Disclosure of information
  • Safety measures and procedures
  • Changes
  • Addressing your concerns about your Personal Information


INFORMATION WE COLLECT AND HOW

“Personal Information” means any information that relates to a natural person, which, either directly or indirectly, in combination with other information capable of identifying such person and includes Sensitive Personal Data or Information which means such personal information which consists of information relating to:

  • password;
  • financial information such as Bank account or credit card or debit card or other payment instrument details;
  • physical, physiological and mental health condition;
  • medical records and history;
  • Biometric information;
  • any other details relating to the above

Provided that, any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as sensitive personal data or information.

Through your use of the Websites, you may choose to provide us with Personal Information that identifies you or any other individual whose information you are authorized to provide. . Some examples of personal information that you may choose to provide TransUnion CIBIL, depending on the Products and Services you use and local law, are: name, address, identity and address proof, PIN code, gender, age, any personal unique identifier (such as PAN), email address, number, payment details, contact information, billing information, loan account numbers, information about third parties, such as references, mentors or contacts, that you provide to TransUnion CIBIL if it pertains to you or if you has their express written consent to do so.

Information we collect automatically

In general, you can visit this Website without telling us who you are or revealing any Personal Information about yourself. We routinely collect certain device-related and analytics information about our visitors and their use of our Websites. We track the Internet Protocol (IP) address from which people visit us/ our Websites for security reasons This IP address does not enable us to identify you by name or contact details, but it does allow us to maintain communication with your unique device during your visit. It also allows us to identify the location and country you are visiting from. We use the information we automatically receive from your web browser to see which pages you visit within our Website, which Website you visited before coming to ours, and where you go after you leave. We develop statistics that are helpful to understand how our visitors can use this Website. We use this information in the aggregate to measure the use of our Website and to administer and improve our Website. This statistical data is interpreted by us in its continuing effort to present the Website content that visitors are seeking in a format they find most helpful.

Certain other information may also be collected from your device automatically, if so permitted by you through your internet browser / device settings, which would be used to display the Websites correctly on your device.

We will not retain personal information that we have collected for a duration longer than is required for the purposes for which the information was collected to be used or is otherwise required to be retained under any applicable law for the time being in force. However, as per the provisions of CICRA, we are required to retain credit information and personal data, as defined under CICRA, for a minimum period of 7 (seven) years from the date of collection.

PURPOSE OF COLLECTION

The information we collect in order to provide our customers and end-users our products and services. Further the information we collect is also used to improve our services to you and/or fulfil obligations/ functions under the applicable laws including CICRA / contractual arrangements with you. You agree that we or our third party service providers collect your IP address or other generic identifier, which would not be capable of identifying you by your name. At times, we also use these identifiers to collect information regarding the frequency with which our guests visit various parts of our Websites.

Personalization. We may combine your credit information or other information collected through cookies and other technical methods with personally identifiable information in order to understand, improve and personalize your online experiences. There are times when we may, with your consent, collect personal information from you such as name, physical and email address, phone number for the purpose of enabling you to avail the services offered by TransUnion CIBIL and to enable TransUnion CIBIL to conduct its activities in accordance with the applicable laws and its contractual arrangements with you. If you choose not to provide the information we request, you can still visit this Website, but you may be unable to access certain options, offers and services.

Provision of Services and other Purposes. If and to the extent permissible under and subject to the applicable laws, TransUnion CIBIL may share your information with third parties (including not limited to its members and partners) for fulfilment of its functions under CICRA or activities ancillary thereto. TransUnion CIBIL discloses information to companies and individuals it employs to perform functions on its behalf. Examples include hosting our web servers, analysing data, providing marketing assistance, processing card payments, providing customer service etc. TransUnion CIBIL may disclose such information to third parties if you consent to such disclosures. If you expressly indicate that you would like to receive information about the opportunities, products or services of third parties, TransUnion CIBIL would supply your contact information to select third parties (including not limited to its members and/or partners), or others for the purpose of sending you e-mail or otherwise communicating with you. Such aggregated data does not identify users of the Website or the end-users individually, and may be made available to various market intermediaries. TransUnion CIBIL may use the information it collects for the Products and Services, to provide, maintain, protect and improve the Products and Services, to develop new ones, and to protect TransUnion CIBIL and our other consumers. TransUnion CIBIL also uses this information to offer you tailored content – like giving you more relevant search results and advertisements. TransUnion CIBIL may use the email address and other details to inform you about TransUnion CIBIL’s Products and Services, such as letting you know about upcoming changes or improvements etc.

You agree that we or any of our members and/or partners may contact you from time to time to provide the offers/ information of such products/ services that we believe may benefit you.

TransUnion CIBIL may disclose and transfer such information to a third party who acquires any or all of TransUnion CIBIL’s business units, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets or by any other permitted way.

DISCLOSURE OF INFORMATION

We may use personal information shared by you or Consumer during the process of registration or otherwise for verification purposes and the customer agrees and allows TransUnion CIBIL to share such information with third parties solely for verification purposes. We may also use the information you provide to update our consumer credit database.

We may provide information so collected from you to government authorities or any court of law as per the applicable laws of India or as per our agreement with our third party service providers or any third party. However, such third party receiving your personal information shall not disclose it further, save and except if required under the any law.

It is possible that we may need to disclose personal information when required by law, such as responses to civil or criminal summons / subpoenas, or other requests by law enforcement personnel. We will disclose such information wherein we have a good faith belief that it is necessary to comply with a court order, ongoing judicial proceeding, subpoena, or other legal process or request to TransUnion CIBIL brought in any country throughout the world, or to exercise our legal rights or defend against legal claims.

Additionally, any disclosure of credit information received by TransUnion CIBIL pursuant to the provisions of CICRA is made only if such disclosure is permitted under the provisions of CICRA. As per the provisions of CICRA, all TransUnion CIBIL’s employees, managers, officers, authorized personnel, agents, sub- contractors and other persons who deal with or have right to access data, information and credit information are essentially required to comply with confidentiality, fidelity and secrecy obligations and sign covenants in this regard.

LINK TO THIRD PARTY SITES

We may link to the websites of other third parties. These third-party websites may collect personal information about you on those Websites, and our Privacy Policy does not extend to these external websites and third parties. Please refer directly to these third parties and web sites regarding their privacy policies. Links to third party sites do not imply endorsement or approval of the sites by TransUnion CIBIL and we cannot accept responsibility for the privacy practices of any websites not controlled by us. We encourage you to review the privacy policies of any third-party sites you visit.

HOW WE COLLECT INFORMATION

Some of our web pages including our third party service providers store and use "cookies" so that we can better serve you with customized information when you return to our site. Cookies are identifiers which a web site can send to your browser to keep on your computer to facilitate your next visit to our site. You can set your browser to notify you when you are sent a cookie, giving you the option to decide whether or not to accept it.

Cookies and other technical methods may involve the transmission of information either directly to us or to another party authorised by us to collect information on our behalf. The information from use of these technical methods may be collected in a form that identifies you personally. You may get cookies from our advertisers. We do not control these cookies, and once you have clicked on the advertisement and left our Website, our Privacy Policy no longer applies.

We also use these technical methods in HTML e-mails that we send you for a number of purposes including: to determine whether you have opened or forwarded those e-mails and/or clicked on links in those e-mails; to customise the display of the banner advertisements and other messages after you have closed an email; and to determine whether you have made an enquiry or purchase in response to a particular email.

APPLICATION

This privacy policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you in search results, sites that may include TransUnion CIBIL services, or other sites linked from our services. This privacy policy does not cover the information practices of other companies and organizations who advertise our services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

SAFETY MEASURES AND PROCEDURES

We will not sell, trade or disclose to third parties any information derived from the registration for, or use of, any online service (including names and addresses) without your consent unless required under applicable law save and except to any of our Members and/or Affiliates for helping you in receiving loans or other purposes in relation to the businesses of our Members and Affiliates and as may be required by legal process or in the case of imminent physical harm to any person. Further, TransUnion CIBIL will allow its Members, Affiliates to access the information for purposes of confirming your registration and providing you with benefits you are entitled to.

Upon withdrawal of consent by you, personal information shared by you or any Consumer will not be used/retained by TransUnion CIBIL for any purposes. You may withdraw the consent by way of unsubscribing from the services offered by TransUnion CIBIL or by sending a written notice of withdrawal to TransUnion CIBIL.

We will take appropriate steps to protect the information you share with us. We have implemented reasonable security practices and procedures, technology and security features and strict policy guidelines to safeguard the privacy of your personally identifiable information from unauthorized access and improper use or disclosure. We will continue to enhance our security procedures as new technology becomes available.

TransUnion CIBIL shall not publish the personal information provided by you without your consent save and except as stated in this Privacy Policy and/or in the General TNC.

Despite these reasonable efforts to safeguard personal information from loss, theft, alteration, or other types of misuse, we cannot guarantee that such loss will never occur. There is always a risk that a third party, without our authorization, might unlawfully access our systems or otherwise access personal information. Whilst we undertake reasonable measure, we are also not responsible for the authenticity of any information which is provided by you or otherwise collected from your use of the Websites, whether personal or otherwise.

CHILDREN’S PRIVACY

The Websites are not intended or designed to attract or be otherwise used by children under the age of 18 years. By using the Websites, you confirm that you are either 18 years of age or more, or an emancipated minor, or possess legal parental or guardian consent, and are fully able and competent to enter into, comply with and be bound by the terms, conditions, obligations, affirmations, representations, and warranties set forth in this Privacy Policy.

Children under 18 years of age should not submit any personal information to us without the express permission of their parent or legal guardian. If you believe that your child has submitted personal information and you would like to request that their information be removed from our systems, please reach out to us at the contact information provided below. We will make reasonable efforts to comply with your request.

CHANGES

We reserve the right to modify this privacy policy at any time, so please review it frequently. If we make material changes to this privacy policy, we will notify the same by means of a notice on our home page. By continuing to use any of our services after notice of changes have been published on the Website, you are consenting to the changes.

If our privacy policy changes in the future, it will be posted here and a new effective date will be shown. You should access our privacy policy regularly to ensure you understand our current policies. TransUnion CIBIL will attempt to respond to all reasonable concerns or inquiries on a best efforts basis within a reasonable period of time.

TransUnion CIBIL may provide notifications, whether such notifications are required by law or are for marketing or other business related purposes, to you via email notice, written or hard copy notice (including via fax), or through posting of such notice on the Website. TransUnion CIBIL reserves the right to determine the form and means of providing notifications to you, provided that you may opt out of certain means of notification as described herein. TransUnion CIBIL is not responsible for any automatic filtering that you or your network provider may apply to email notifications we send to the email address you provide us.

We may choose to use testimonials/ feedback provided by you via email or on the Website for marketing purposes. By making any suggestions, feedback or comments on our Website, for our people and services, you have agreed to allow us to publish the same for marketing purposes by TransUnion CIBIL.

GOOGLE ADWORDS REMARKETNG

Explanation:
This website (www.transunioncibil.com) and/or other channels such as mobile applications uses Google Adwords Remarketing services to help analyze consumer behavior. Whenever consumer visits our website, google system (Adwords Remarketing) would drop cookies (a packet of small data text files with id tags) on consumer’s system. Once consumer leaves our website and goes to some other website which have content or website relevant to our website (like Banks), Google would display our ads on those websites based on cookies which were dropped earlier by Google (while consumer was on TransUnion CIBIL’s website). It could mean that we advertise to previous visitors who haven’t completed a task on our site, for example using the contact form to make an enquiry. Any data collected will be used in accordance with our own privacy policy and Google’s privacy policy.

Privacy of Collected Data:
We will never use the statistical analytics tool to track or to collect any Personally Identifiable Information (PII) of visitors to our site. TransUnion CIBIL will not link, or seek to link, an IP address with the identity of a computer user. We will not associate any data gathered from this site with any Personally Identifiable Information from any source.Information to Google Adwords privacy policy can be found at the following link- https://support.google.com/adwordspolicy/answer/143465?hl=en

Information About Google Remarketing:
This website uses Google Remarketing to advertise online using text or image ads on the Google Display Network. Remarketing is a feature that lets us reach people who have previously visited our site, and show them relevant ads when they visit other sites on the Google Display Network.

Website Terms And Conditions:
In order to undertake Remarketing, Google has instructed to include certain terms in our website terms and conditions such as - We utilize Google Analytics features which are implemented based on Display Advertising (e.g., Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, or Google Analytics Demographics and Interest Reporting).

TransUnion CIBIL uses Remarketing with Google Analytics to advertise online. Third-party vendors, including Google may show TransUnion CIBIL ads on sites across the Internet.

TransUnion CIBIL and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on website visitors past visits to our website.

TransUnion CIBIL and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to TransUnion CIBIL site.

TransUnion CIBIL would use data from Google's Interest-based advertising or 3rd-party audience data (such as age, gender, and interests) with Google Analytics.

In order to opt out of Google Analytics for Display Advertising / Remarketing consumer can access Google Analytics' Google Analytics Opt-out Browser Add-on at following link https://tools.google.com/dlpage/gaoptout/. . Consumers can customize Google Display Network ads by using the Ads settings for their respective google accounts

By accessing the Website, providing personal information for inclusion in TransUnion CIBIL’s database, or by using the Products and Services, you hereby consent to your information being stored, used, altered, modified, compiled, dis-assembled, shared and disseminated as described here, by TransUnion CIBIL and its Affiliates.

ADDRESSING YOUR CONCERNS ABOUT YOUR PERSONAL INFORMATION

Any requests, questions, clarifications or grievances with respect to this Policy or about your Personal Information can be sent to our Grievance Officer at:
Name: Ms. Berly Varghese, Grievance Officer Postal address:
TransUnion CIBIL Limited
One World Centre, Tower 2A, 19th Floor, Senapati Bapat Marg, Lower Parel, Mumbai – 400 013.
Email address: [email protected]
Helpline number: 022-61404300 (from Monday to Friday between 10 am to 6 pm)

If you wish to receive a response by email or mail, please be sure to include your name and postal address or email address, as the case may be.

All grievances shall be redressed in an expeditious manner. Subject to complete details in relation to the grievance being provided, the Grievance Officer shall redress all grievances within a maximum period of 30 days from the date of receipt of the grievance.

GOVERNING LAW

This Privacy Statement is governed by the laws of India. Any action, suit, or other legal proceeding, which is commenced to resolve any matter arising under or relating to this Policy website, shall be subject to the exclusive jurisdiction of the courts at Mumbai, India.