1. Who We Are
[YOUR COMPANY NAME] ("TrueLine Credit", "we", "us", "our"), CIN: [YOUR CIN], NBFC Reg. No.: [YOUR REG. NO.], is the data controller for personal information collected via this website and mobile application. Registered Office: [YOUR REGISTERED OFFICE ADDRESS].
2. Information We Collect
We collect the following categories of data, strictly on a need-to-know basis for credit assessment and loan servicing:
2.1 Personal Identification Data
- Full name, date of birth, gender
- PAN Card number (for KYC and credit bureau check)
- Aadhaar number (masked after verification; used for identity verification only)
- Passport / Voter ID / other address proof (as applicable)
2.2 Contact & Location Data
- Mobile number (linked to Aadhaar)
- Email address
- Residential address, city, state, PIN code
2.3 Financial & Employment Data
- Monthly income, employment type, employer name
- Bank account number, account type, IFSC code (for disbursal/repayment)
- Salary slips, bank statements (for income verification)
2.4 Loan Application Data
- Loan amount, tenure, purpose, repayment date
- Application timestamp, IP address, device information
- UTM / referral source (for marketing attribution)
2.5 Behavioural / App Data (if applicable)
- One-time access to camera / selfie for live photo KYC (with explicit consent)
- One-time access to location for KYC purposes (with explicit consent)
- We do NOT access: contact list, call logs, SMS (other than OTP), media files, telephony functions
3. How We Use Your Data
- Loan assessment: Credit evaluation, identity/KYC verification, income verification
- Loan servicing: Disbursal, repayment management, collections, account statements
- Regulatory compliance: Credit bureau reporting (CIBIL, Experian, CRIF), RBI reporting requirements
- Fraud prevention: Identity verification, anti-money laundering checks
- Customer communication: Application updates, repayment reminders, OTPs
- Marketing (optional, with consent): Loan offers, financial tips, promotional communications
4. Consent
All data collection requires your prior, explicit, and informed consent with a full audit trail. Specifically:
- You will be asked to consent separately for: KFS acceptance, terms/privacy, data usage, credit bureau check, and marketing communications
- The purpose of each data collection is disclosed at the point of collection
- You have the right to deny or withdraw consent at any time by writing to privacy@trueline.credit
- Withdrawal of mandatory consent may result in inability to process your loan application
5. Your Rights
Under RBI Digital Lending Guidelines 2022 and applicable Indian data protection laws, you have the right to:
- Access: Request a copy of your personal data we hold
- Correction: Request correction of inaccurate data
- Deletion: Request deletion or anonymisation of your data (subject to legal retention obligations)
- Data portability: Receive your data in a portable format
- Restrict processing: Object to or restrict specific uses of your data
- Revoke consent: Withdraw any previously given consent
To exercise these rights, email: privacy@trueline.credit
6. Data Sharing
We share your data only with:
- Credit bureaus: CIBIL, Experian, CRIF — as mandated by law
- eKYC providers: UIDAI (Aadhaar) authentication agencies
- Technology/cloud service providers: Hosting, SMS, email services (under data processing agreements)
- Regulatory authorities: RBI, law enforcement (when legally required)
We do NOT sell your personal data to any third party. Any third parties with access are listed in this Privacy Policy. We obtain your explicit consent before sharing data with any third party not listed here.
7. Data Storage & Security
- All personal data is stored exclusively on servers located within India (per RBI Digital Lending Guidelines, Para 11.4)
- Data is encrypted at rest (AES-256) and in transit (TLS 1.3)
- Access to your data is restricted on a least-privilege basis
- Biometric data (if any) is not stored in our systems
- We maintain a clear data retention and destruction policy
8. Data Retention
| Data Category | Retention Period |
|---|
| Loan application data | 7 years after loan closure (per RBI/IT Act) |
| KYC documents | 5 years after account closure (per PMLA 2002) |
| Marketing data | Until consent withdrawn or 2 years of inactivity |
| Rejected applications | 2 years |
9. Cookies & Tracking
Our website uses cookies for session management, analytics, and marketing attribution (UTM). You can manage cookie preferences through your browser settings. We do not use cookies to track sensitive financial behaviour across other websites.
10. Changes to This Policy
We may update this Privacy Policy periodically. Material changes will be communicated via registered email or SMS at least 7 days before taking effect. Continued use of the platform after changes constitutes acceptance.
11. Contact — Data Privacy
Privacy Officer: [Your Privacy Officer Name]
Email: privacy@trueline.credit
Address: [Registered Office Address]