Privacy Policy

Last Updated:
September 2023

*The Privacy Policy has been updated in accordance with the Digital Personal Data Protection Act, 2023

1.  Introduction

1.1   Recur Club Technologies Private Limited (“Company”, “we” or “us”) is committed to protecting your Personal Data and respecting your privacy. Accordingly, we have developed this privacy policy (“Privacy Policy”) in order for you to understand how we collect, use, store, transfer, and disclose Personal Data that you have chosen to share with us when you use the services on the website https://www.recurclub.com (“Platform”). The services we offer you on or through the Platform are referred to as the “Services”.

1.2  The terms and conditions for the use of the Services are available at https://www.recurclub.com/terms-of-use (“Terms of Use”). Please read this Privacy Policy with the Terms of Use and not in derogation of it  before registering to use our Services. All capitalised terms not defined in this Privacy Policy shall have the meaning ascribed to them in the Terms of Use.

1.3   In this Privacy Policy, references to “you”, “your” and “User” are to you, an individual who is an end user of the Platform, irrespective of whether you are acting in your capacity as an individual user or on behalf of the company or organisation you work for or represent. 

1.4   If there’s any dispute with regards to the provision(s) of the Privacy Policy and that of any other agreement(s) regulating your access to services provided by us, it is rendered that such agreement shall prevail over the Privacy Policy.

1.5   We   encourage   User   to   read   this   Privacy   Policy   regarding   the   collection,   use,   and disclosure of information by User from time to time to keep itself updated with the changes & updated that we make to this Policy.

2.  Definitions
In this policy, unless the context otherwise requires -
(a)  “Person” includes—
(i)  an individual;
(ii)  a Hindu undivided family;
(iii)  a company;
(iv)  a firm;
(v)  an association of persons or a body of individuals, whether incorporated or not;
(vi)  the State; and
(vii)  every artificial juristic person, not falling within any of the preceding sub-clauses;

(b)  “Personal Data” means information that relates to an individual, which either directly or indirectly is capable of identifying such person.

(c)  “Data Fiduciary” means any person who alone or in conjunction with other persons determines the purpose and means of processing of personal data.

(d)   “Data Principal” means the individual to whom the personal data relates.

3.  Your Consent

3.1   By sharing Personal Data or accessing, using, or registering to use the Services,  you consent to the collection, storage, use, processing, transfer and disclosure of Personal Data in accordance with this Privacy Policy.

3.2   We are required to collect your Personal Data to provide you with access to the Platform and Services. In certain cases, we are required to collect Personal Data as required by law, or under the Terms of Use. If you fail to provide us that data as and when requested by us, we will not be able to perform our obligations under the arrangement we have with you or are trying to enter into with you (for example, to provide you with features of the Services). In this case, we may have to cancel or limit your access to the Services (or part thereof).​

4.  Data We Collect About You and Use of Data

4.1   To facilitate the provision of Services to you, we may be required to collect information about you or the organisation that you represent. This Privacy Policy sets out our practices and procedures in connection with the processing of Personal Data. Personal Data does not typically include information about businesses or organisations.

4.2   We collect different categories of Personal Data in connection with the Services, which we have grouped together as follows: 

(a)  Identity and Profile related Data and KYC Data, which includes your name, username and designation within the organisation or company that you represent while availing the Services, documentary proof of your identity, such as details of or pertaining to your PAN card, your Aadhaar, your driver’s license, your voter ID, your passport, etc. 

(b)  Contact Data, such as your email address and contact number. 

(c)  Technical Data, which includes your IP address, browser information including browser type and version, time zone setting and location, corresponding location details, operating system and platform, device details, and other technology on the devices you use to access the Platform. 

(d)  Usage Data, which includes information about how you use the Services. 

(e)  Marketing and Communications Data, which includes your preferences in receiving marketing from us and our third parties and your communication preferences. 

4.3   Please note that we only collect and process a minimal amount of your Personal Data to provide you with the Services. We collect, use, store, and transfer your Personal Data only after obtaining your consent, to provide you with, or in connection with, the Services. 

4.4   We may use aggregated data in connection with our Services. Aggregated data could be derived from your Personal Data but is not considered Personal Data under law as it does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

4.5   By providing your Personal Data, you are authorising the Company and its representatives to connect with you and to offer you our Services for the following uses and purposes (“Purpose(s)”):

(a)  to operate your account on the Platform;
(b)  to register you as a user and to provide the Services effectively;
(c)  to decide whether to offer you our Service;
(d)  to facilitate your application to avail and otherwise in connection with your obtaining of credit facilities including our lending partners;
(e)  to manage our relationship with you, including notifying you of changes to any Services; 
(f)   to perform studies, research and analysis for improving our Services, business and the Platform;
(g)  to administer and protect our business and the Platform, including troubleshooting, data analysis, system testing, and performing internal operations; 
(h)  to use data analytics to improve the Platform, our products and Services, marketing, customer relationships, and your experiences;
(i)    to ensure that the content and advertising displayed are customized to your requirements from the Platform;
(j)    to provide you with customer support and resolve related issues;
(k)   to contact you via phone, SMS, email or third-party communication services for technical issues, payment reminders, or the Platform-usage related announcements and other security announcements;
(l)    to enforce our Terms of Use;
(m)  to obtain necessary rankings/ratings from various agencies (including CIBIL);
(n)   to undertake KYC verification;
(o)   to respond to legal notices, court orders or any other legal process or to establish or exercise our legal rights to defend against legal claims;
(p)   to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our Terms of Use, breach of our agreement with you or as otherwise required by law; 
(q)   to comply with the Reserve Bank of India’s norms, to contact you or locate you in case of any default;
(r)    to ensure compliance with applicable laws;
(s)   and for any other purpose as the Company may deem fit in respect of the Services, subject to applicable law for the time being in force.​

5. How We Collect Data About You 

5.1  We use different methods to collect and process Personal Data about you. This includes: 

(a) Information you provide us: This is the information (including Identity and Profile related Data, KYC Data and Contact Data) you consent to give us when you use our Services or when you correspond with us (for example, by email or chat, or through the Platform). It includes information you provide when you register to use the Services, create an account on the Platform, use a Platform feature, share data through the Platform, enter a promotion, or survey, or when you give us feedback or contact us. If you contact us, we will keep a record of the information shared during the correspondence. 

(b) Information we collect about you and your device: Each time you visit the Platform or use the Services, we will automatically collect Personal Data using tools like cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites that employ our cookies.

(c) Information from third party sources: We may collect Personal Data about you from third party sources. We ensure that such collection occurs in accordance with law or upon your consent. 

5.2  Please note that we do not have any control over any data that you may choose to make publicly available. For example, if you post reviews, comments, or messages on public sections of the Platform or on an application store (such as the Play Store), you do so at your own risk. We are not liable for any third-party misuse of such data. 

6. Disclosure, Transfer and Retention of Data

6.1  We may share your Personal Data with the parties set out below in furtherance of the Purpose: 

(a)  Internal third parties, which are the other entities in our group of companies. 

(b)  External third parties, such as: 

- service providers who provide IT, technology-enabled KYC and system administration services.

- professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.

- Banks, Non-Banking Financial Institutions, Financial Institutions and Investors

- regulators and other authorities. 

(c)  Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the manner set out in this Privacy Policy. 

(d)  Third parties who have a need or authority to receive such information, if we have a good-faith belief that access, use, or disclosure of the information is reasonably necessary to comply with: (i) direction of any authority having to receive such information under law; ii) any order of court; (iii) detection, prevention, or otherwise addressing fraudulent, security or technical issues; (iv) protecting against harm, the rights, property or safety of the Company, our users or the public as required or permitted by law. In this regard, the Company shall have no obligation to inform you of such disclosure.

(e) Third parties for the enforcement of the Terms of Use for using and accessing the services offered by us available/accessible at (https://www.recurclub.com/terms-of-use)

6.2  Data Retention: You agree and acknowledge that your Personal Data will continue to be stored and retained by us as required or permitted by applicable laws or regulatory requirements, or as required for defending future legal claims. All the other details will be deleted upon the request of the customer for the deletion of the data, provided there is no active loan or Service being availed by you. However, in some instances, we will be unable to facilitate requests for the deletion of your data in compliance with legal
obligations, or in accordance with applicable laws, which may require us to store data for longer periods of time.

6.3  Data Destruction: Upon completion of the retention period for each category of Personal Data as described above, we shall delete or destroy, to the extent technically possible, Personal Data in our possession or control, or render the Personal Data into anonymised data, so that it no longer constitutes Personal Data. 

6.4  Transfer of Personal Data: All your Personal Data, including financial data, is only stored on servers and systems located in India. We shall not transfer your Personal Data to any third country. 


7.  Data Security 
We implement appropriate security measures to protect your Personal Data from unauthorised access, and follow technology standards prescribed by applicable law, including the Information Technology Act, 2000, Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and The Digital Personal Data Protection Act, 2023, and directions issued by the Indian Computer Emergency Response Team.

8.  Your Legal Rights 

8.1.
 Under certain circumstances, you have the right to:

(a)  Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you. 

(b)  Request the erasure of your Personal Data: This enables you to ask us to delete or remove Personal Data. We shall comply with any request, subject to applicable laws, the terms of the loans that are sanctioned through the Platform and Section 5.2 above.  

(c)  Right to deny consent: This enables you to deny us the consent necessary to process your Personal Data. If you exercise this right, it may impact or restrict our ability to provide Services to you. 

(d)  Right to revoke consent: This enables you to withdraw consent at any time. We shall comply with any request, subject to applicable laws, the terms of the loans that are sanctioned through the Platform and Section 5.2 above. 

(e)  Request the correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate Personal Data we hold about you corrected, though we may need to verify the accuracy of the new Personal Data you provide to us.

(f) Right to Know Recipients of Shared Personal Data. This enables you to know the identities of all other Data Fiduciaries and Data Processors with whom your personal data has been shared by us, along with a description of the personal data so shared.

(g) Right to Nominate. This enables you to nominate any other individual, who shall, in the event of death or incapacity of the Data Principal, exercise the rights of the Data Principal.

8.2.  We will facilitate your request to exercise such rights subject to the provisions of applicable laws relating to the processing and storage of Personal Data. If you wish to exercise any of the rights set out above, please write an email to the Grievance Officer, whose details are mentioned in Section 13 of this Privacy Policy, providing in as much detail as possible, the right(s) you wish to exercise. Please also include a description of the Personal Data you believe we hold or process about you, so that we may be able to locate such Personal Data. In the event that we need additional information from you, our Grievance Officer will contact you further.

9.  Cookies

9.1  Cookies are small data files that are stored on your device. We use cookies and other tracking technologies to distinguish you from other users of the Services and to remember your preferences. This helps us provide you with a good experience when you use our Services and also allows us to improve the Services. 

9.2  We identify you by way of using cookies. The cookies shall not provide access to data in your device such as email addresses or any other data that can be traced to you personally. The data collected by way of cookies will allow us to administer the Services and provide you with a tailored and user-friendly service. The cookies shall enable you to access certain features of the Services. Most devices can be set to notify you when you receive a cookie or prevent cookies from being sent. If you prevent cookies from being sent, it may limit the functionality that we can provide when you visit the Platform or try to access some of the Services.

9.3  In the event your cookies are enabled, we may place cookies on your machine that store small amounts of data on your device about your use of the Platform. Cookies can identify the pages that are being viewed and this can assist us in tracking which of our features appeal the most to you and what content you may have viewed on past usages. These technologies are used in analysing trends, administering the site, tracking users’ movements around the Platform and to gather demographic information about our user base as a whole. 

10.  Links to other Third-Party Websites

This Platform may from time to time contain links to other third party websites of our partner networks, service providers, financial institutions, advertisers, and affiliates (“Third Party Links”).  Please note that the Third Party Links that may be accessible through our Platform are governed by their respective privacy policies. Please check their privacy policies before you submit any Personal Data to such websites or use their services. We do not accept any responsibility or liability for the policies or for any Personal Data that may be collected and subsequently used by third parties through such Third Party Links. 

11.  Changes to Privacy Policy
The Company reserves the right to change, modify, add, or remove portions of this Privacy Policy at any time for any reason at its absolute and sole discretion. You can access the latest version of this Privacy Policy at any given time on the Platform and it shall be your responsibility to stay updated on any changes to this Privacy Policy. Once posted, those changes are effective immediately, unless stated otherwise. Your visit on the Platform is deemed to be your acceptance for the terms and conditions and practices described in Privacy Policy and in case you disapprove the terms and conditions then you should immediately cease to use the Platform. ​It is also important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us. When you use our Services, we make best efforts to provide you with the ability to review and correct inaccurate or deficient data, subject to any legal requirements

12.  Grievance Redressal

In case of any grievance / any changes you may need to make to your Personal Data you may contact the Grievance Officer at: 

Name: Mr Mohd Sohaib
Phone Number: +91-639-578-7927
Email Address: privacy@recur.club