The Paisayaar online digital lending platform (“Paisayaar”) is owned and operated by JingleCred Digital Finance Limited, a company incorporated under the provisions of the Companies Act, 2017, holding CUIN 0214242 (“Company”) and licensed as a non-banking finance company with license no SECP/LRD/78JDFL/2022-85. The Company is engaged in the business of providing micro and nano-loans to its customers in Pakistan through the Paisayaar APP on Google play (which term includes the Paisayaar mobile application (the “Application”) only.
The Company is committed to protecting and respecting your privacy. This Privacy Policy has been formulated to assist you to understand how your personal information will be collected, stored and processed by the Company when you visit the Website or Application.
All users or customers of the Website or Application are advised to read and understand this Privacy Policy carefully, as by accessing the Website or Application you agree to be bound by the terms of this Privacy Policy and consent to the collection, use, disclosure, storage, and protection of your personal information in accordance with this Privacy Policy, or any changes made hereto.
This Privacy Policy is subject to change or modification from time to time without prior notice and it is advised that you regularly review our Privacy Policy as available on the Application or Website to keep up to date with any changes made.
References below to “you” or “customer” shall mean any visitor, user, business partner, agent, supplier, vendor or customer of the Company or its Application or Website and shall include a “User”. References to “we” or “us” shall mean the Company and/or the Paisayaar Platform.
1. When this Privacy Policy applies.
1.1 This Policy applies when you access, sign-up, provide information, upload or supply documents or otherwise use or subscribe to the Company’s products, services, applications, websites or networks, all of which are subject to the terms of this Privacy Policy. This includes data, video, advertising, internet and other products, services and applications. This Privacy Policy also applies to other websites owned or operated by the Company.
1.2 This Privacy Policy also applies to you and anyone who uses our products or services under your account, except where we identify that a separate privacy policy or terms and conditions apply. You are responsible for making sure you understand this Privacy Policy.
1.3 You must agree to and be willing to accept the terms of this Privacy Policy before you may visit or use the Paisayaar Platform, or any products or services offered therein.
1.4 This Privacy Policy and any additional terms of use apply to you even if you are not our customer and you interact with us as part of running our business, such as by:
a. accessing any of our products or services accessible through any Paisayaar Platform;
b. when using any of our products or services;
c. generally enquiring about our services or products.
d. when entering any promotion;
e. when calling our help desk; or
f. when you download the Paisayaar mobile application, or sign-up or create an account on Paisayaar or any other mobile application belonging to the Company.
1.5 If you need to give us personal information about someone else in relation to our products and services, this Privacy Policy will also apply.
1.6 Depending on the product or services, you may also receive service-specific and/or region-specific terms. You will be legally bound by both this Privacy Policy and the service/region specific term to the extent that you have accepted them when signing up to any service or product; therefore, you are required to read these terms carefully.
1.7 It is your responsibility to ensure that all personal data submitted to the Company are correct. You are responsible for maintaining the accuracy and completeness of personal data and keeping the data up-to-date.
2. What Information We Collect
2.1 The Company is committed to protecting all Personal Information (defined below at clause 2.2) of its employees, customers, business partners, suppliers, contractors and other parties that the Company will engage with.
2.2 To help ensure safe lending practices, may use and collect your location, camera, calendar, Phone model and status, Reference contacts, Application activity, Customer information and Collaborator. We will upload information to our servers through these permissions (see below). If you click Reject, we may not be able to provide you with a loan. We will also not be able to access or upload your personal information, or perform credit checks on you.
a. Location: Your location, device, and usage data can be used for credit modeling and anti-fraud purposes.
b. Camera: When applying for a loan, you need to use your camera to scan the CNIC certificate. After taking the photo, the relevant information will be automatically filled in, this is to reduce the input errors and saving you valuable time. For the security of your loan account, a living photo will be verified to compare whether the current operation is yours. We will collect and ask you to upload CNIC photos and live photos. We assure you that the uploaded photos are only for user loan approval and will not access the gallery or photos on your device. Your consent will be sought again when applying for camera permission.
c. Calendar: It is used to remind you of the repayment date and avoid the impact of overdue repayment on your credit.
d. Phone model and status: Our application collects and monitors specific information relevant to your mobile device, including its hardware model, component, RAM, storage and unique device identifiers (e.g. IMEI, serial number, SSAID, AAID, SIM information). We will upload your device information to our servers to provide you with additional financial convenience. We will also use this information to assess the loan applicant's income level and match this information with other information about the applicant to determine the applicant's credit worthiness and loan requirement.
e. Reference Contacts: Only require the borrowers enter the reference contacts in the loan application for reference contact person and enable us to contact them to verify the identity of the customer and the reference by CALL/SMS, prevent fraud and track collections. We will upload the contact information to the Paisayaar server https://data.paisayaar.pk in a secure network environment.
f. Application activity: We need access to the activity in the application, including package name, application name, time of first installation and time of application updates, to assess whether the customer is eligible for a loan. We will upload this information to our servers at https://data.paisayaar.pk encrypted for the purpose of identifying and analyzing behavior and risk in multiple loans to assess whether the loan can be processed, which helps prevent fraud.
g. Customer information: Our application collects customer account data, which includes the user's email address and public profile information such as name, photo, ASID. Our application also verifies the mobile phone numbers though OTP on the device, uniquely identifying it and preventing fraud and unauthorized access.
h. Collaborator: The SDK that we connect with Deeplink third-party services is released through multiple social networks such as Google and Facebook. Distinguishes the attribution source of user channels and transmits the identity of each channel. Deeplink and Paisayaar do not obtain or use any information from users' private accounts.
2.3 Data retention and deletion
The information provided by the uploaded CNIC and facial photos is only used for detecting and verifying the authenticity of your identity, as well as confirming whether the facial photo on the current operating app matches the CNIC, ensuring they belong to the same individual.
The above data shall be stored for 1 year from the date of acquisition. If the customer wants to delete the data, they can send a request to customer service at the following email: support@paisayaar.pk and we can manually delete the data within 3-5 business days.
3. What we use the information for
3.1 Information collected by us (or where applicable and necessary, the parties stated at clause 3.3) shall be used for the purpose of determining whether or not to provide a financial service or product to you, the amount of such exposure and the terms and conditions applicable to such services or product.
3.2 We access, store and use the information we collect from you to provide our services and develop new products. We use personal information to provide the services you request in order to customize your user experience and improve our services. If we intend to use your personal information to promote any products to you, we will provide you with the ability to opt-out of such uses.
3.3 We share your personal information with other partners, as described in this Privacy Policy, when services are provided by partners authorized by us. In addition, we may share personal information with our affiliates and subsidiaries.
3.4 We use your information to power our services and to improve your experiences and interaction with the Company.
3.5 We use your information to provide, support, improve, protect, analyze and bill for our products and services; to communicate with you about your service, products or applications; to market our products and services; to detect and avoid fraud; for advertising; and for research purposes. We may use information we collect from you when you purchase a product or service from us, sign up for our newsletter, respond to a survey or marketing communication, surf the Website or Application, if you register for an online account with us, download and register on one of our apps or use certain other site features in the following ways:
a. personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested;
b. improve our website/app in order to better serve you;
c. allow us to better service you in responding to your customer service requests;
d. administer a contest, promotion, survey or other site feature;
e. ask for ratings and reviews of services or products; and
f. follow up with them after correspondence (live chat, email, phone inquiries, or WhatsApp, either directly with the user or with and through an authorized person of reference whose information has been provided by the user to the Company
3.6 This means we may:
a. record details about the products and services you use or order from us;
b. send you product or service-information messages (we may send you messages to confirm your order and tell you about any changes that might affect your service, like when we have infrastructure work planned or need to fix something);
c. let you create and log in to the online accounts we run;
d. charge you and make sure your payment reaches us; and
e. give information to someone else (if we need to for the product or service you’ve ordered) or to another communications provider if you’re buying some services from them and us.
3.7 In addition, we use the following information to provide products and services and manage your account:
a. your contact details and other information to confirm your identity and your communications with us. This includes your Personal Information and other relevant credentials;
b. your payment and financial information;
c. your communications with us, including emails, webchats and phone calls. We will also keep records of any settings or communication preferences you choose; and
d. information from cookies placed on your connected devices that we need so we can provide a service.
4. When we may disclose information to third parties
4.1 We may disclose some or all of the data we collect from you when you download or use the Paisayaar Platform to connect to mobile wallet providers, credit bureaus, or other partner financial institutions. We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
4.2 We may also use a third-party payments services provider or payments processing company to process payments and repayments, transfer money to your Operative Account or any other user account, process other payments, and to provide additional products and services, and may therefore disclose your information to such third-party payments services provider.
4.3 We may disclose your personal information to any local or international law enforcement officers or competent regulatory or governmental agencies, in good faith belief that such disclosure is reasonably necessary to enforce any terms and conditions and/or this Privacy Policy, to assist in the prevention, detection, investigation or prosecution of criminal activities or fraud.
4.4 We shall use your data for the purposes of compiling statistics relating to our user base or financial product or services and may disclose such information to any third party for such purposes, provided that such information will always be anonymous.
4.5 We may use other third-party companies to monitor site traffic, which may, in some instances, store customer information. Where we use another organization, we still control your personal information and we have strict controls in place to make sure it’s properly protected.
4.6 We may also disclose or transfer your personal information to third parties in the event that:
a. the Company is involved in a merger, bankruptcy, acquisition, reorganization, liquidation, or sale of assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
b. the Company or substantially all of its assets are acquired by a third party, personal data held by it about its customers will be one of the transferred assets;
c. the Company is under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request; or
4.7 In order to enforce any terms and other agreements or to investigate potential breaches; report defaulters to any credit bureau or for the purpose of publishing statistics relating to the use of Paisayaar Platform, in which case all information will be aggregated and made anonymous.
4.8 We may use your Personal Information, or any other information obtained as stated in this Privacy Policy to contact you, via SMS.
5. Tracking and Cookies
5.1 “Cookies” are small text files transferred by a web server to users’ hard drive and thereafter stored on their computer. The types of information a cookie collects include the date and time users visited, their browsing history, preferences, and username.
5.2 The Company may use Cookies to manage our users’ sessions and to store preferences, tracking information, and language selection. Cookies may be used whether customers register with us or not.
5.3 In some instances, our third-party service providers may use cookies on the Paisayaar Platform. We cannot control or access cookies used by third-party service providers. This Privacy Policy covers only Cookies used by us, and not any Cookies used by third parties.
5.4 Customers may have the ability to either accept or decline the use of Cookies on their computer, whether registered with us or not. Typically, you can configure your browser to not accept Cookies. However, declining the use of Cookies may limit your access to certain features of Paisayaar Platform. Cookies help us to provide you with a good experience when you use the Paisayaar Platform or browse any of the websites and also allow us to improve the Paisayaar Platform and any other of our websites.
5.5 We will not use Cookies for any purposes not stated in this Privacy Policy. You can clear all the Cookies stored on your computer, and most web browsers provide the option of blocking Cookies. However, by doing so, you have to change the user settings every time you visit our website.
5.6 In addition to Cookies, we may also use other similar technologies on the Paisayaar Platform such as web beacons and pixel tags. For example, when you receive an email from us, it may contain a click-through URL that links to our web page. If you click the link, we will track your visit to help us learn about your preferences for products and services and improve our customer service. A web beacon is a transparent graphic image embedded in a website or application or in an email. We use pixel tags in emails to find out whether an email has been opened. You can unsubscribe from the mailing list at any time if you do not want to be tracked in this manner. By using the Website or Application and accepting this Privacy Policy, you consent to the use of Cookies, web beacons and pixel tags as described above.
We retain the above information to resolve necessary disputes, provide support to users, and resolve issues permitted by law.
6. Limitations on the Use and Disclosure of your Information and Exercise Access, Rectification, Cancellation and Opposition (“ARCO”) Rights
6.1 To the extent required by applicable laws, you have the right to access your personal information collected and the details of their treatment, as well as to rectify them if they are inaccurate or cancel their use through a written request addressed to the following email address support@paisayaar.pk or by submitting a letter within the office facilities of the Company during office hours on working days, said requirements will be attended on priority basis. Please note that deleting or withdrawing information may affect the services we provide to you. If there is any change in personal information made by you, you must provide supporting documents related to the change of personal information for verification by the company.
6.2 To exercise ARCO rights, an application must contain and accompany the following:
a. The full name of the user, address and email account or any means to communicate the response to the request.
b. The documents that prove the identity or, where appropriate, the legal representation of the user.
c. The clear and precise description of the Personal Information on which you wish to exercise any ARCO Rights.
d. In the case of requesting a rectification, the documentation that supports the requested rectification must be attached.
e. the Company reserves the right to request additional information and/or documentation to that mentioned in order to meet the request.
6.3 The Company will not be obliged to delete any personal information when (i) it is necessary for performing the contract obligations, (ii) it is subject to the applicable laws, (iii) it is necessary to comply with an obligation legally acquired by the user.
6.4 You may also at any time oppose the processing of data that is not essential for the legal and/or commercial relationship that you establish with the Company, which you may do through the procedure indicated here.
6.5 In the processing of your personal information, it is primarily anticipated that its protection is against any damage, loss, alteration, destruction, and against any unauthorized use, access or treatment.
7. Security Practices and Safety Precautions
7.1 We adopt reasonable security practices and procedures, to include, technical, operational, managerial and physical security controls in order to protect your personal information from unauthorized access, or disclosure while it is under our control. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential.
7.2 The data and information we collect from you may be transferred to, and stored at, a destination i.e., e. it is encrypted and stored on the Paisayaar Platform or Company server. The staff members at the destination may be engaged in the fulfillment of your requests. By submitting your personal information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
7.3 Our security practices and procedures limit access to personal information on need-only basis. Further, our employees are bound by code of conduct and confidentiality policies which obligate them to protect the confidentiality of personal information.
7.4 We maintain the security of our Paisayaar Platform, however, for reasons outside of our control, security risks may still arise. Any personal information transmitted to us or from our online products or services will therefore be your own risk. However, we will use all reasonable efforts to ensure the security of your information. We observe reasonable security measures to protect your personal information against hacking and virus dissemination.
7.5 Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Paisayaar Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, but we cannot guarantee the security of your data transmitted to our Paisayaar Platform; any transmission is at your own risk. Once we have received your information, we will use procedures and security features to try to prevent unauthorized access, to the extent reasonably practical.
7.6 You agree that the Company or any of its affiliates, associated or related entities, employees, directors, shareholders, agents, representatives etc. shall have no liability towards you in case of any unintended security breach which results in unauthorized access to, or disclosure of, your information. You agree to waive, to the fullest extent permitted by law, all of your rights to seek damages or otherwise hold the Company and its related entities liable for any security breach resulting in disclosure or unauthorized access to your information.
8. Privacy Control and Permissions
8.1 Regarding the information we collect and how it is collected, you have specific choices that may control what information we collect after using your device. For example, you can modify the permissions on your Android or iOS device to access camera or audio permissions or delete your account on the Paisayaar Platform. You can also delete content from our servers, subject to applicable laws, by requesting us via email at support@paisayaar.pk.
8.2 Once you have deleted your account, you will no longer be able to use the services via Paisayaar Platform. The Company reserves the right to retain your personal information in accordance with relative applicable laws and regulations for a retention period required by the laws. Upon the expiration of the retention period, we will remove or anonymize your personal information.
8.3 Your written request may be required for security. When you object to, or restrict our use of your personal data, this may affect the services we provide to you. We may decline the request if we have reasonable grounds to believe that the request is fraudulent, unfeasible or may jeopardize the privacy of others.
9. Link to other websites or applications
The Paisayaar App might share the links to other websites on promotion. Please be aware of these other websites, they may collect your personally identifiable information. We are not responsible for the privacy practices or content of these linked websites.
Only apply Paisayaar App application on Google Play to ensure safety of your personally identifiable information.
10. Your Consent to the Collection, Storage, Use and Disclosure of Information
10.1 By using the Paisayaar Platform and/or by providing your information, you agree to the collection and use of the information you disclose or that generated as a result of your use of our service on the Paisayaar Platform in accordance with this Privacy Policy, including but not limited to your consent to the collection, use, sharing and disclosure in accordance with this Privacy Policy your message. If we decide to change our Privacy Policy, we will post these changes on the Website or Application so that you can always know what information we collect, how we use it, and under what circumstances we disclose it.
10.2 By providing us with your contact information, including home or mobile phone number, we obtain your permission to contact you or the authorized person of contact whose details have been provided by you to the Company through SMS, manual or pre-recorded voice messages and automatic dialing technology, WhatsApp, email, live-chat, and post, for all purposes that are not prohibited by applicable laws. Message and data rates may apply. The purpose of the call and information includes; suspected fraud or identity theft; obtaining information; transactions or services of your account; collecting your account or collecting accounts that are in arrears. The rights granted to us in this section are extended to our company’s affiliates, subsidiaries, agents, suppliers, ultimate holding company or its subsidiaries.
10.3 Subject to applicable laws, you have the right to withdraw your consent for such collection, store and process of your information at any time by cancelling your account from your device, provided that you have no obligation pending towards the Company. You can revoke the consent granted to the Company, in order to stop using them, for which the procedure indicated in section 6 of this Privacy Policy must be followed. You can withdraw your consent for further collection of this information at any time by logging out and uninstalling the Company mobile or other applications from your device.
10.4 We process your personal data based on your consent. However, withdrawal does not affect the legitimacy and effectiveness of how we process your personal data based on your consent before the withdrawal is made; nor does it affect any data processing based on another justification other than your consent.
11. Protection of Minors
We place great value on the protection of minors’ personal information. As required by applicable laws and regulations, any user under the age of 18 should be banned to use our service. As the parent or statutory guardian of a minor, it is your responsibility to prohibit your child from using our service. Otherwise, all legal consequences are borne by yourself.
12. Disputes
With respect to any disputes regarding this Privacy Policy including but not limited to any provisions related to indemnification, limitation of liability relating to damages, choice of law and dispute resolution forum, we ask you to first submit any such complaints directly to us the relevant customer services desk or helpline.
13. Contact Us
Please contact us if you need help:
Company name : JingleCred Digital Finance Limited
Principal Business: Nano Lendings
Status of company: NBFC (Investment Finance Service)
License No. : SECP/LRD/78/JDFL/2022-85
Date of License issued: March 10, 2023
Product name: Paisayaar
Contact us by email: support@paisayaar.pk
Contact us by phone: 051-111-883-883
Service Timing: 9:00-18:00
Address: Fortune Residency, Ground Floor,Street no. 26, National Police Foundation,E11/4, Islamabad.