On visiting this web application collectively, the “Platform” and availing the services provided by us “Services” you agree to be bound by the terms and conditions of this Privacy Policy.

By access to the Platform or any part thereof, you ‘Data Principal’ expressly and unambiguously render your consent to Think360.ai “we” or “our” or “us” or “Think360.ai”, in processing of your personal data in accordance with this Privacy Policy and the Digital Personal Data Protection Act, 2023.

This Privacy Policy is incorporated into and subject to the Terms of Use of the Platform.

For the purpose of this Privacy Policy, the users of the Services may be customer/consumers, or any other persons using Services or accessing our Platform “user” or “you” or “your”.

Collection of Personally Identifiable Information

When you use our Platform or our Website, we collect and store your personal data only with explicit consent and for lawful purposes under the Digital Personal Data Protection Act, 2023. We collect personal information only to provide you with a safe, efficient, and customized experience and services.

While you may browse the Website without sharing your identity and other personal details, creating an account requires certain basic information to deliver personalized services. Where possible, we indicate the mandatory and the optional fields. You always have the option to not provide your personal information by choosing not to use a particular service or feature on the Platform.

• Your full name
• Email
• Mailing address
• Phone number

Users have the right to refuse consent, withdraw consent at any time, and exercise rights of correction, erasure, and portability.

Collection of Mobile Number and Email Address

When you sign up with us, we collect your mobile number and email address to uniquely identify you. Such identifiers shall be processed only for authentication and fraud prevention, in compliance with the DPDP Act.

Collection of Location

We shall collect and process location data from your device, only with explicit consent, limited to the purpose of fraud prevention and account security.

Collection of SMS Data Explicit Consent Required

Subject to your explicit prior consent, we process and securely store non-personal financial and transactional SMS data from your device solely to verify your income, analyse financial behaviour, and categorize cash flow, credits, and spending patterns to facilitate our Services including credit assessment, where applicable.

Our access is strictly limited to SMS messages originating from 6-digit alphanumeric senders such as banks, financial institutions, and authorized service providers. We do not collect, read, transmit, or store any personal SMS messages, private communications, One-Time Passwords OTPs, or sensitive account credentials.

Collection of Other Non-Personal Information

We automatically track certain information about you based upon your behaviour on our Platform. We use this information to do internal research on our users’ demographics, interests, and behaviour to better understand, protect, and serve our users and improve our services. This information is compiled and analysed on an aggregated basis.

We also collect your Internet Protocol IP address and the URL used by you to connect your computer to the internet, etc. This information may include the URL that you just came from whether this URL is on our Website or not, which URL you next go to whether this URL is on our Website or not, your computer browser information, and your IP address.

Cookies are small data files that a Website stores on Your computer. We will use cookies on our Website similar to other lending websites and online marketplace websites. Use of this information helps Us identify You in order to make our Website more user-friendly. Most browsers will permit You to decline cookies but if You choose to do this it might affect service on some parts of Our Website.

Use and Disclosure of Information

We access, store, and use the collected information to provide services as requested, customize user experience, drive research and develop new ones.

We use personal information to:

• Resolve disputes;
• Troubleshoot problems;
• Help promote a safe service;
• Analytical analysis;
• Measure consumer interest and satisfaction in our products and services;
• Inform you about online and offline offers, products, services, and updates;
• Customize your experience;
• Detect and protect us against suspicious or illegal activity, fraud, and other criminal activity;
• Enforce our terms and conditions;
• Improvement of our services and as otherwise described to you at the time of collection.

In our efforts to continually improve our product and service offerings, we collect and analyse demographic and profile data about our users’ activity on our Website. We shall not process personal data for marketing unless separate consent is obtained. Users may opt-out at any time.

Retention & Deletion

We retain personal data only for the duration necessary to fulfill the purpose of processing or as mandated by law. Upon withdrawal of consent or completion of purpose, data shall be erased in accordance with the DPDP Act.

Changes in This Privacy Policy

Think360.ai reserves the right to change, modify, or update this Privacy Policy at any time. Changes will be posted on the Website and take effect immediately unless stated otherwise. We encourage you to periodically review this page for the latest information on our privacy practices. Continued access or use of the Services constitute Your acceptance of the revised Privacy Policy.

Accessing Your Information / Contacting Us

Users may choose to edit/modify or delete/withdraw any Personal Information shared for use on the Platform at any time. Please note that deletion or withdrawal of information may affect the Services we provide to you. In case of modification of Personal Information, Users will be required to furnish supporting documents for the purpose of verification by the Company.

Security Precautions

The Website intends to protect your personal information and to maintain its accuracy as confirmed by you. We implement reasonable physical, administrative, and technical safeguards to help us protect your personal information from unauthorized access, use, and disclosure. For example, we encrypt all sensitive personal information when we transmit such information 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 endeavour 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 the law.

We blend security at multiple steps within our products with state-of-the-art technology to ensure our systems maintain strong security measures, and the overall data and privacy security design allows us to defend our systems ranging from low-hanging issues up to sophisticated attacks.

In addition, the Website has been certified for the following security certifications:

• ISO 9001: being the international standard that details requirements for a quality management system QMS. Organizations use the standard to demonstrate the ability to consistently provide products and services that meet customer and regulatory requirements with the requisite security protections.
• ISO 27001: is a specification for an information security management system ISMS and is the suggested level of certification required under the Information Technology Act, 2000. An ISMS is a framework of policies and procedures that includes all legal, physical, and technical controls involved in an organization’s information risk management processes.
• ISO 14001: is an internationally agreed standard that sets out the requirements for an environmental management system. It helps organizations improve their environmental performance through more efficient use of resources and reduction of waste, gaining a competitive advantage and the trust of stakeholders.

We work hard to protect from unauthorized access, alteration, disclosure, or destruction of information we hold, including:

• We use encryption to keep your data private while in transit;
• We review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems;
• We restrict access to personal information to our employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
• Compliance & Cooperation with Regulations and applicable laws;
• We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it.

Data Transfers

We maintain your information on servers located in India. Cross-border transfers, if undertaken, will comply with the Digital Personal Data Protection Act, 2023 and applicable legal frameworks. Formal written complaints are addressed promptly, and unresolved matters may be escalated to the Data Protection Board of India or other appropriate regulatory authorities.

Bureau Enquiry

We will enquire with one or more Credit Bureaus on one or more affiliate National Banking Financial Company’s NBFC behalf to provide you with your loan amount.

Links to Other Sites

Our Website may link to external sites that may collect your personally identifiable information. We are not responsible for their privacy practices or content. Please review the privacy policies of any linked sites, as their practices may differ from ours.

Our Website may link to external sites that may collect your personally identifiable information. 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. Please review the privacy policies of any linked sites, as their practices may differ from ours.

Support

If you believe your personal data has been breached or have any questions, queries or complaints with respect to the Website, please contact our Grievance Officer at legal@think360.ai or alternatively, you can write to

Grievance Officer,
Legal Manager,
B 2078,
Oberoi Garden Estate,
Chandivali, Andheri East,
Mumbai 400072