Policies and Codes
- Purpose
The Reserve Bank of India (‘RBI’), vide its Master Direction- Non-Banking Financial Company-Non-Systemically Important Non-Deposit taking Company (Reserve Bank) Directions, 2016, (‘NBFC Master Directions’), mandates all NBFCs to ensure that a suitable mechanism exists for receiving and addressing complaints from its customers and resolving such complaints in a fair and expeditious manner.
Accordingly, IBL Finance Private Limited (‘IBL Finance/Company’) has adopted and put in place the following ‘Policy’ parallel to the Company’s Fair Practice Code (‘FPC’), in accordance with the NBFC Master Directions, as amended from time to time.
- Objectives
- Objectives
This Policy has been formulated to develop a robust framework for addressing and resolving the complaints and grievances raised by the customers. It shall be ensured by the Company that:
- Customers are treated fairly and impartially at all times;
- Complaints raised by customers are dealt with courtesy and in a timely manner;
- Customers are informed of the mechanism to escalate their complaints within the organization, and their rights if they are not satisfied with the resolution of their complaints by the Company;
- Officials of the Company strive towards working in good faith and without prejudice towards the interests of the customers.
- Grievance Redressal Officer and Principal Nodal Officer
- Grievance Redressal Officer and Principal Nodal Officer
3.1. The Board shall nominate an employee/officer of the Company as the Grievance Redressal Officer (‘GRO’) who shall be entrusted with the duty of addressing and resolving the grievances raised by the customers, including complaints nd issues relating to digital lending.
3.2. The GRO will be available during office hours to receive the grievances of all customers. In the event the GRO is not available, the immediate senior officer in the Company shall attend to the customer.
3.3. The Board shall also appoint a Principal Nodal Officer at their head office who shall not be a rank less than a General Manager or an officer of equivalent rank and shall be responsible for representing the Company and furnishing information on behalf of the Company in respect of complaints filed against the company.
- Grievance Redressal Mechanism
- Grievance Redressal Mechanism
4.1. Lodging of compliant
4.1.1. The Company shall ensure that all locations, where the Company is having its operations as well as through its application/ website, have a dedicated set-up to address customer grievances/ complaints to ensure prompt grievance redressal.
4.1.2. All grievances made by the borrowers will be electronically recorded and maintained by the Company at its principal place of business and in each of its offices/branches(if any).
4.1.3. The Company shall ensure that the customers quote their application number/sanction number/loan account number in all their correspondence with the Company. Anonymous complaints shall not be addressed under this mechanism.
4.1.4. The Company shall endeavour to provide an acknowledgement to complaints received from its customers.
4.2. Resolution process and time frame
4.2.1. If the customer has any grievance in respect of the services provided by the Company, the customer shall contact the Company’s Customer Service Department (‘CSD’) through any of the following channels:
Email at: info@iblfinance.in
A letter may be alternatively sent at the address: Office No. 1001, World Trade Centre, Nr. Udhna Darwaja, Ring Road, Surat, Gujrat 395002
Website: www.iblfinance.in
4.2.2. If the customers are not satisfied with the resolution received from the above channel or if the customers do not hear from us in 15 (fifteen) days, the customer may escalate the complaint to the GRO through email or contact on the contact number below. The customer may also approach the registered or branch office of the Company, in-person, to lodge a complaint.
Details of the GRO are as follows:
Grievance Redressal Officer
Name: Grievance Redressal Officer
Email ID- info@iblfinance.in
Address: off. No. 1001, World Trade Centre, Nr. Udhna Darwaja, Ring Road, Surat, Gujrat 395002
Tel: +91 93281 16200
4.3. The Company shall endeavour to resolve the complaints and grievances of customers within reasonable time. The customer shall be kept informed about the status of their complaints.
4.4. Certain types of cases might need additional time due to the nature of the activities involved; for e.g. retrieval of documents. The Company shall inform the customers of such delay and provide expected timelines for resolution of the complaint.
4.5. If the complaint is not resolved within one month of lodging of the complaint, or if the customer is not satisfied with the response of the Company, the customer may lodge their complaint to the Consumer Education and Protection Cell (CEP Cell) on the email id : (email: crpc@rbi.org.in or on their online portal: https://cms.rbi.org.in/.
The complaint shall contain the name and address of the complainant, the department against which the complaint is being made, and facts of the case supported by documents, if any, relied upon by the complainant.
The Officer In-Charge
Consumer Education and Protection Cell
Reserve Bank of India
3rd Floor, Nr. Income Tax
Ashram Road
Ahmedabad-380 014
Telephone: 079-27540955
Email: crpc@rbi.org.in
4.6. Alternatively, the customer may also approach the Officer-in-Charge of the Regional Office of Department of Supervision of RBI:
The General Manager,
Department of Non-Banking Supervision, Reserve Bank of India,
Near Gandhi Bridge, Ahmedabad- 380 014.
Tel: 079-2754 3057/ 5651
E-mail: dnbsahmedabad@rbi.org.in
- In case of outsourcing
- In case of outsourcing
5.1. The provisions of this Policy shall also extend to deal with the issue relating to services provided by the outsourced agency, in case the Company has outsourced any of its functions.
5.2. The GRM, in no way, shall be compromised on account of outsourcing.
- Additional requirements in case of digital lending
- Additional requirements in case of digital lending
6.1. In case of digital lending, as defined under the RBI Guidelines on Digital Lending, the Company shall ensure that the GRM and the Lending Service Providers (‘LSPs’)
1 engaged by them shall have a suitable Grievance Redressal Officer to deal with FinTech/ digital lending related complaints/ issues raised by the customers. In this case, the GRO of the Company shall also handle all such issues related with digital lending.
6.2. Contact details of Company’s GRO shall be prominently displayed on Company’s website, as well as on the websites of the LSPs and on the Digital Lending Application (‘DLA’) 2 and also in the Key Fact Statement3 provided to the customer. Further, the facility of lodging complaints shall also be made available on the DLA and on the website as stated above.
6.3. If any complaint lodged by the customer against the Company or the LSP engaged by the Company is not resolved by the Company within one month, he/she can lodge a complaint with the above RBI officers in the same manner as provided in this Policy. In any case, the responsibility of grievance redressal shall continue to remain with the Company.
- Display of details of redressal mechanism
- Display of details of redressal mechanism
7.1. The Company shall prominently display, on its website/app, details in respect of Grievance Redressal Mecha, i.e., name and contact details, telephone no., email address of the Customer Service Department and the GRO.
7.2. In addition to the display on the website, the above-mentioned information shall also be displayed in the offices of Company where business is transacted. In this case, the Company may display the information in English as well as a vernacular/regional language.
- Miscellaneous
- Miscellaneous
8.1. The Company follows a strict no-discrimination policy and does not does not discriminate against persons with any disability. In furtherance of the ethos and values of the Company, the Company shall ensure the redressal of grievances of persons with disabilities under the GRM.
8.2. It shall create awareness about the GRM and educate its customers about it.
- Review
- Review
The Board shall conduct quarterly review of the functioning of the GRM at various levels of management. This Policy shall be reviewed at such periodicity as decided by the Board, subject to at least one review annually.
- IBL Finance Private Limited (‘IBL’ or ‘the Company’) is a Non-Banking Financial Company (NBFC) registered with the Reserve Bank of India (RBI). The Company has framed and adopted the Fair Practices Code (“the Code”) which sets the
fair practice standards while dealing with individual customers. The Code has been prepared based on the Guidelines issued by the RBI.Objectives of the fair practices code
The Code has been adopted:
- A) To promote good and fair practices by setting minimum standards in dealing with customers;
- B) To increase transparency so that the customers can have better understanding of what they can reasonably expect of the services;
- C) To encourage market forces through competition, to achieve higher operating standards;
- D) To promote a fair and cordial relationship between customers and the Company;
Background
The Reserve Bank has prescribed the Directions on Fair Practices Code applicable to Non-Banking Financial Companies (NBFCs). The Directions, inter alia, cover general principles on adequate disclosures on the terms and conditions of a loan, collections/ recovery mechanism, protection of customer’s rights, changes in terms & conditions, Grievance Redressal etc.
Applicability
The Code shall apply to all employees of the Company and other persons authorized torepresent it in the course of its business.
Non-discrimination policy
The Company will not discriminate between its customers on the basis of gender, physical ability, race or religion. The Company will also not discriminate visually impaired or physically challenged applicants on the ground of disability in extending products, services, facilities, etc. However, this does not preclude the Company from instituting or participating in schemes framed for different sections of the society.
Language of the communication
All required communications by the Company to the borrower will be in the language as understood by the borrower (English or Vernacular language).
Applications for loans and their processing
- A) Loan application forms will include the relevant information which affects the interest of the borrower so that informed decision could be taken by the borrower. The loan application form will also indicate the documents
required to be submitted with the application form. - B) Receipt of completed application forms will be duly acknowledged by the Company and will also indicate the approximate time frame within which the customer can expect to hear from the Company regarding his/ her loan application.
Loan appraisal and terms and conditions
- A) All loan applications will be assessed as per the Company’s internal credit policies and appraisal process;
- B) Upon approval of the loan a sanction letter indicating the amount of loan sanctioned, the applicable annualised rate of interest rate method of application of the same along with other important terms and conditions will
be conveyed in writing to the borrower; - C) The Company will mention the penal interest charged for the late payment in bold in the loan agreement. A suitable provision in this regard shall be incorporated in the loan agreement;
- D) After the execution of the loan agreement, all the borrowers will be furnished a copy of the loan agreement along with a copy each of all enclosures quoted in the loan agreement.
Disbursement of loans including changes in terms and conditions
- A) Any changes in the terms and conditions (which are adverse to the borrower) including rate of interest rate, service charges, prepayment charges, repayment/ disbursement schedule etc. shall be informed to the borrower in
writing; - B) Changes in interest rates and other charges (which are adverse to the borrower) shall be with prospective effect only;
- C) Decision to recall any loan shall be done in accordance with the terms and conditions of the loan agreement;
- D) All underlying securities shall be released, as per the request of the borrower, after the full repayment of the loan and all other charges in connection with the loan in terms of the loan agreement is complete and subject
to exercise of any right of set off, for which a notice shall be given to the borrower with full details.
Privacy and confidentiality
All Personal Information of the borrowers shall be treated as Private and Confidential, and shall be guided by the following principles & policies. We shall not reveal Information or data relating to borrower accounts, whether provided by the customers
or otherwise, to anyone, including our affiliates other than in the following exceptional cases:- If the information is to be given by law.If the information is to be given by law.
- If there is a duty towards the public to reveal the information.
- If our interests require us to give the Information (for example, to prevent fraud) but it shall not be used as a reason for giving information about the borrower or borrower’s accounts (including customer came & address)
to anyone else for marketing purposes. - If the borrower asks us to reveal the information, or with the borrower’s permission.
- If we are asked to give a reference about a borrower, we shall obtain his / her written permission before giving it.
- The borrower shall be informed the extent of his / her rights under the existing legal framework for accessing the personal records that we hold about him / her.
- We shall not use borrower’s personal information for marketing purposes by anyone including ourselves unless the customer specifically authorizes us to do so.
General provisions
- A) The Company shall refrain from interference with the business of the borrowers except under the terms and conditions of the loan agreement (unless new information, not disclosed earlier, by the borrower has come to the notice
of the Company); - B) Where the borrower insists on transferring the loan, the consent or otherwise the objection if any, would be conveyed within 21 days from the date of receipt of such request of the borrower. Such transfer will be as per
the terms and conditions of the loan in consonance with law; - C) For recovery of loan, the Company will not resort to undue harassment and will follow procedures adopted internally by the Company within the applicable legal framework;
- D) The Company will comply with the extant regulatory provisions with respect to prepayment of loans by its borrowers.
- E) We will ensure that the staff is adequately trained to deal with the customers in appropriate manner.
Grievance redressal mechanism
As a customer, if you have any feedback/ suggestions or grievances with respect to the services offered by IBL Finance Private Limited (hereinafter referred to as ‘the Company’), you may please write to the Company’s Customer Service
Department through any of the following channels:- Call At :- +91 93281 16200
- Email – info@iblfinance.in
- Website – www.iblfinance.in
- You may write a letter at the address 1001, World Trade Centre, Nr. Udhna Darwaja, Ring Road, Surat, Gujrat 395002
- How a complaint should be made:Customers are requested to necessarily provide necessary loan details i.e. Loan Account Number, Details of Feedback/ Suggestion/ Complaint and valid Contact Information including phone no. & e-mail ID while lodging
communicating with the Company. - When to expect a replyThe Company shall endeavor to address/respond to all queries/grievances within reasonable time and keep the customer in informed about the status of their complaints. Each customer query/ complaint being unique in nature,
may take up to 4 weeks for complete resolution after investigation. - Whom to approach for redressal
Customers are requested to first raise their concerns through any of channels mentioned above. In case of delayed or no response from the respective channel within the specified timelines, such complaint may be escalated to the Grievance Redressal Officer
of the Company whose details are as given below:Name Grievance Redressal Officer Email ID info@iblfinance.in Address 1001, World Trade Centre, Nr. Udhna Darwaja, Ring Road, Surat, Gujrat 395002 Tel +91 93281 16200 - Escalation to the Reserve Bank of India
If the Customer does not receive any response from the Company within 4 weeks or is dissatisfied with the response received, he/ she may approach the Reserve Bank of India at the following address:
The General Manager, Department of Non-Banking Supervision, Reserve Bank of India, Near Gandhi Bridge, Ahmedabad- 380 014. Tel: 079-2754 3057/ 5651 E-mail:
info@iblfinance.in
Policy for determining interest rates
- A) To ensure that the customers are not charged excessive interest rates and charges on loans and advances by the Company, the Board of Directors of the Company has adopted a Policy on Interest Rate Model and Policies &
Procedures on Determining Interest Rates. - B) The information regarding the Interest Rate Model of the Company will be also disclosed in the application form and sanction letter.
Use of Information and Materials
The Content (material, information, data, news items, software, text, images, graphics, video and audio etc.) contained on this Website is provided for general information only and should not be used as a basis for making business/commercial decisions (including investment decisions). User is advised to exercise due caution and/or seek independent advice before entering into any arrangement or financial obligation based on the Content contained on this Website. The Content contained in this Website, including text, graphics, links or other terms are provided on an “as is”, “as available” basis and are protected by copyright in favour of Operator. User should not distribute text or graphics to others without the express written consent of the Operator. User should not copy, download, publish, distribute or reproduce any of the Content contained on this Website in any form without prior permission of the Operator. Use of the products or services described at this Website may not be permitted in some countries and if in doubt, User should check either with the local regulator or authority or with the Operator before requesting further information on such products/ services. Products and services are available only at the discretion of Operator, subject to the individual contractual terms and conditions of products and services on which they are offered and such products and services may be withdrawn or amended at any time without notice. The full range of products or services may not be available in all locations.Links to Other Sites
The Website may offer links to sites that are not under the Operator’s control. If the Users visit any of these linked sites they should review each site’s terms of use. Specifically, the Operator does not assume any responsibility for any obligations of any persons who offer, provide or mediate services or goods on such sites. The Operator is neither responsible for the policies and practices of other companies nor for the contents of linked third-party sites. We recommend that the User reads the privacy policy and terms of website use of each such website to find out how they protect the User’s Customer Data.Creation of User Account for availing Services
To obtain the Loan(s) or to avail other services from us from time to time, the User has to create an account (“User Account”) with us by registering himself/ herself. You are solely responsible for maintaining the secrecy of your user id and password for the User Account and shall be responsible for all activities that occur in connection with your User Account. In case of any unauthorized use of your User Account the same shall be intimated to us. You shall not create multiple User Accounts and shall not use your User Account for any purpose that is unlawful, illegal or forbidden by law. As a consideration for availing Loan/ Service through Website, you may be required to pay certain fee, charges, interest or cost as may be applicable as mentioned in our Website or as per the terms for respective products and services as prescribed by us. You understand that application of loan through online means is dependent on technical factors which inter alia includes your connectively to internet, your ability to make payment through online means which in-turn is depended on payment services from your bank or similar service providers, capability of the computer or phone which you use for the purpose, your careful approach in reading the terms, understanding the same and following the process. You have sole responsibility for adequate protection and back up of data and/or equipment and for undertaking reasonable and appropriate precautions to scan for computer viruses or other destructive properties. We make no representations or warranties regarding the accuracy, functionality or performance of any third party software that may be used in connection with the Website. For the purpose of creating the User Account through the Website:- You shall be an Indian citizen resident in India and minimum 18 years of age
- You shall not be a person either barred or otherwise legally prohibited from taking Loan or availing services offered by us
- You should have an updated UID (Aadhaar) number and Permanent Account Number (PAN) or such other valid identity proof and residential address proof as described by Reserve Bank of India and prescribed by us for Know Your Customer requirements
- You shall not impersonate any person or entity or falsely state or otherwise misrepresent age, identity or affiliation with any person or entity.
- You have valid email address and valid mobile number where you want to receive OTP and other communications from Operator.
- You have a bank account in India (bank name, IFSC, branch and account number) having enabled internet banking facility for the purpose of transfer/ receipt of funds.
- You should be either salaried employee or self-employed or pensioner.
- You have read and understood the Privacy Policy, Policy on Website Use as well as General Terms and Conditions for obtaining Personal Loan from IBL Finance Private Limited’ (GTC) for availing loan from Operator.
- Your desktop/ mobile device should have:
- Supported Resolutions: 1366 x 768+. Best viewed on 1366 x 768
- A working internet connection having HTML supported Web Browsers: Chrome 55+, Firefox 49+, Edge 38+ or Mobile Browsers: Latest version of Chrome, Firefox, Safari Browser
- Latest version of Adobe Reader: https://get.adobe.com/reader/
- A web camera
Prohibited Conduct
By using our Website you agree that you shall not:- use our Website for spamming or illegally interfere with security, integrity, networks connected therewith and operation related features of our Website or features that enforce limitations on the use of Website;
- Infringe ours or any third party’s intellectual property rights, rights of publicity or privacy;
- post or transmit any message data, image or program which violates any law or which is libelous, defamatory or which discloses private or personal matters concerning any person;
- Refuse to cooperate in an investigation or provide confirmation of your identity or any other information you provide to us;
- upload any content that constitutes negligent advice or contains any negligent statement or instructions, an incitement to commit or promote a crime or criminal activity; or any content which is in contempt of any court, or in breach of any court order or any law for the time being force or threatens the unity, integrity, defense, security or sovereignty of any country, or public order;
- Use the facilities and capabilities of Site to conduct any activity or solicit the performance of any illegal activity or other activity which infringes the rights of others;
- Breach these Terms or any other policies which we have; and
- Use Site to collect or obtain personal information, including without limitation, personal information about other users of our Site.
Copyrights and Trademarks
All copyright and all intellectual property rights in all material presented on the Site (including but not limited to text, audio, video or graphical images), trademarks and logos appearing on this site are the property of the Operator and/ or its affiliates and/ or third parties who have an arrangement with the Operator to provide services to the User. The User is further required to observe the Operator’s copyrights of this Website and, furthermore, to observe the third parties’ rights to material and text posted by the Operator on the Website (including, but not limited to, trademarks, logos etc.) but owned by third parties and which is under the protection of appropriate laws on the protection of intellectual property rights. You do not have the right to use any of our trade names, trademarks, service marks, logos, domain names, and other distinctive brand features. You do not have the right to remove, obscure, or alter any proprietary rights notices (including trademark and copyright notices), which may be affixed to or contained within the services. You will not copy or transmit any of the services. We neither represent nor warrant that your use of materials displayed at the Site will not infringe rights of third parties.Breach of the Terms
Without prejudice to our rights under this Policy, if you breach these terms & conditions and in any way, or if we suspect that you have breached these terms & conditions of Website use in any way, we may (i) send you one or more formal warnings; (ii) temporarily suspend your access to Website; (iii) permanently prohibit you from accessing Website; (iv) block the device using the IP address or International Mobile Equipment Identity Number from accessing Website; (v) contact any or all of your internet service providers and request that they block your access to Website; (vi) commence legal action against you, whether for breach of contract or recovery of amounts due or damages or otherwise; and/or (vii) suspend or delete your account on Website. The User herein agree to indemnify and hold us harmless from and against any and all claims, action, liability, cost, loss, damage, endured by us by your access to the Website.No Warranty and Limitation of Liability
This Website may contain advice/ opinions and statements of various professionals/ experts/ analysts, etc. Operator does not represent/ endorse the accuracy, reliability of any of the opinions/ statements/ information by such person. Reliance on these statements shall be at the risk of the user of this Website. The Operator does not guarantee the accuracy, correctness, completeness, timeliness or availability of this Website’s contents and/or services and does not accept any responsibility (e.g. towards the Users of the Website) in this respect. It is the responsibility of the User of this Website to independently verify and evaluate the accuracy, completeness, reliability and usefulness of any opinions, services or other information provided on this Website. No information sent to any client through this Website or available on this Website shall constitute any representation or warranty by the Operator, or its subsidiaries or affiliates regarding the credit-worthiness, financial performance or prospects, solvency, or viability of any company or other legal entity or the business carried on by such entity. The User is fully liable for any risk for his use of this Site and the Operator does not assume any responsibility or liability for such risk. IBL Finance Private Limited, its subsidiary companies, its affiliates, and their directors and employees (Entities) accept no liability and will not be liable for any loss or damage arising directly or indirectly (including special, incidental or consequential, punitive, or exemplary loss, damage or expenses) from use of this Website by any User or any linked site or inability to use by any party, howsoever arising, and including any loss, damage or expense arising from, but not limited to, any defect, error, omission, interruption, imperfection, fault, mistake or inaccuracy with this Website, its Contents or associated services, or due to any unavailability of the web site or any part thereof or any contents or associated services even if the Entities are advised of the possibility of such damages, losses or expenses. Due to the nature of the Internet transactions, use of or access to the Website may be subject to interruption, transmission blackout, delayed transmission and incorrect data transmission. The Operator is not liable for malfunctions in communications facilities not under its control that may affect the accuracy or timeliness of messages and transactions you send. By accepting this terms or using this Website or by expressing intent or by making application for availing any loan or services, you confirm that you have understood the intricacies, the related risks and the process, you also confirm the aspects mentioned aforesaid are beyond control of the Operator. Hence, any of your acts will be at your choice and discretion and therefor you disclaim us from claim or damages suffered by you or for loss of profit.Dispute resolution and governing law
The use of this Website and the Policy on Website Use shall be governed by Indian law. The Policy on Website Use and your activity under this Policy are an ‘electronic record’ in accordance with the (Indian) Information Technology Act, 2000. Any dispute arising in connection with the use of Website shall be settled before courts of Suart (India) and in accordance with Indian law. Should any provision of this Policy be held invalid or unenforceable for any reason, the invalid or unenforceable provision shall be severable from the remaining provisions and shall not affect the validity or enforceability thereof.Changes to Website or Policy
The Operator reserves the right to modify the appearance, contents, organization, location and accessibility of the Website and/ or the Policy at any time without prior notice. The publication of any data or information on the Website, with the exception of this Policy on Website Use, will not be considered as an act in law, unless expressly stated otherwise. The User is expected to keep himself/ herself updated of any changes made in this Website and the information available on it on a regular basis and Operator undertakes no responsibility about advising the User about any such changes. Though Operator will endeavor to ensure that information contained on this Site is obtained from sources which, it feels, are reliable, Operator does not warrant such information’s completeness or accuracy. Use of the Website after the republication of amended Policy is deemed to represent the User’s consent with the amended Policy on Website Use.Introduction
IBL Finance Private Limited(IBLFIN) is committed to protect the personal and financial information submitted by our customers and would endeavor to protect such information from unauthorized use.This Privacy Policy applies to all applicants/customers applying for loans orvalue added services through our mobile application “IBL : Instant Personal Loan” or using website of IBL Finanance. At IBL Finance Private Limited(IBLFIN), we are committed to protecting your personal data and respecting your privacy. Please read the following terms of the Policy carefully to understand our practices regarding your personal data and how we will treat it. This Policy sets out the basis on which any personal data we collect from you, we collect about you, or that you provide to us, will be processed by us. By giving us consent to process your personal data, you accept that we will collect, store and use your personal data in accordance with this policy.
The Data/Information We Collect About You
We collect or use and store personal information about you in connection with providing the services to you, after obtaining your consent. Please note that we only collect and process the minimum necessary details of your personal data or information to provide the services to you. For the purpose of credit risk assessment, we need the following permissions from you.
* Identity and personal data:
This includes your first and last name, date of birth, gender, selfie, educational qualifications, income source, monthly income and contact information (including addresses, email IDs and phone numbers).
* KYC data:
This includes identification documents issued by the government or other authorities, and includes details of or pertaining to your Aadhaar or PAN card.
* Data from SMSs:
We will request permission to collect, transmit and store your SMS messages for the purpose of to verify and analyse your financial position, to determine your cash flow, credits, income, and spending pattern and data from SMSs store on our secured IBL Finance Private Limited(IBLFIN) server. Post collecting all SMSes, IBL Finance Private Limited(IBLFIN) will only store financial SMSes sent by 6-digit alphanumeric senders, which helps us to identify the various accounts held by the user and to help perform an optimal ‘credit risk assessment’ of the user. We will only store messages that are relevant to this purpose and will not store irrelevant or personal messages in any form or manner. The permission is voluntary and can be revoked at any time. However, denying access may lead to an inaccurate assessment of the borrower’s credit assessment on the platform.
* Location data:
We only collect and monitor information about your device location for KYC verification, after obtaining your express consent, or to perform risk assessments for credit scoring.
* Contact data:
We collect, store and use contact information for fraud prevention, security and compliance. Also, we request users to provide us with contact references for the purpose of filling the reference details screen during the loan application stage.
* Device data:
Collect and monitor specific information about your device including your hardware model, operating system and version, unique device identifiers like IMEI and serial number, user profile information and mobile network information to uniquely identify the devices and ensure that unauthorized devices are not able to act on your behalf to prevent frauds.
* Storage Data(Images Or Documents):
We collect and monitor the required KYC images or documents and also take the user’s selfie with the user’s permission, for KYC verification and complete the loan application process. We collect, transmit and store above mentioned all data on our secured IBL Finance Private Limited(IBLFIN) server. We do not access your mobile phone resources such as files and media (except as disclosed above to enable you to upload documents), call logs and telephony functions. We do not collect your biometric data. 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. 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).
Consent of The Users
When a user applies for any loan or finance from us, we first obtain the user’s authority/consent (by means of e-signature, ‘I agree’ tick box, one time password, yes/no authentication etc). Users give their consent that his/her customer data will be stored and processed by us for various purposes. A customer has the right to access and correct their customer data by contacting IBL Finance Private Limited(IBLFIN). While using the IBL Finance Private Limited (IBLFIN) website or mobile application, you agree not to engage in illegal or unauthorized activities in any way (including hacking, cracking or defacing any part of the site).
Data / Cookies
We may set cookies to track your use of the Application. This is used to enhance your experience with our app. We use cookies to help recognize who you are, so your login experience is smooth every time. Cookies also allow us to collect non-personally identifiable information from you, such as which pages you visited. Using this information helps us create a more user-friendly experience for all visitors. By using the application, you indicate your consent to our use of cookies. Please note that if you reject or delete these cookies, some parts of the application may not function properly.
Use of User Information
By submitting User information to IBL Finance Private Limited(IBLFIN), User expressly acknowledge and consent to use of such information in a manner specified under this Policy. User information can be used for various purposes including without limitation the following:
-
- * Verifying User identity.
- * To facilitate the user using the IBL Finance Private Limited (IBLFIN) platform.
- * To obtain credit reports and evaluate your creditworthiness for availing the loan / facility from IBL Finance Private Limited (IBLFIN).
- * Extending loans and financial services to the user from regulated entities including but not limited to banks, NBFCs, NBFC-P2P, other financial partners, etc.
- * To ensure compliance of all legal obligations of lending partners for the purposes of facilitating loans / financial services, Know Your Customer, Prevention of Money Laundering, CKYRC requirements etc.
- * For fraud prevention and detection.
- * To diagnose technical problems, provide support and assist users in troubleshooting issues.
- * To send communications, notifications and receive promotional offers.
- * To prepare, review and file reports as required by applicable law.
- * To understand User preferences, requirements.
- * To allow the User to participate in the interactive features offered by the IBL Finance Private Limited (IBLFIN).
- * To improve content and protect the integrity of IBL Finance Private Limited (IBLFIN).
- * To increase / improve the products / services offered on IBL Finance Private Limited (IBLFIN).
- * To ensure compliance with all applicable laws.
Disclosure of information
We respect that you do not want your personal information to be shared with other companies at any time. However, we may require to share your Personal Information/ Sensitive Information with our affiliates, business and non-business partners including but not limited to credit information companies, where we feel that you will be assisted better for the purpose of underwriting and approval of your loan or any other financial product transaction/related transaction. We share information as described below in accordance with this privacy policy. We will keep your personal information confidential and limit access to it to those who specifically need it to conduct their business activities, except as otherwise permitted by applicable law.
* Third party service providers:
We may employ other companies and individuals, call centers, payment gateways, banks to perform functions on our behalf. Examples include delivering e-mail, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links) and providing customer service. They have access to personal information needed to perform their functions, but may not use it for other purposes. Further, they must process the personal information in accordance with this Privacy Policy and as permitted by applicable law.
* Business Transfers:
As we continue to develop our business, we might sell or buy business units. In such transactions, customer information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy (unless, of course, the customer consents otherwise). Also, in the unlikely event that IBLFIN’s, India’s assets or substantially all of its assets are acquired, customer information will of course be one of the transferred assets.
* Protection of App:
We release personal information when we believe, release is appropriate to comply with the law; enforce or apply our User Terms and Conditions and other agreements; or protect the rights, property or safety of App, our users or others. This includes exchanging information with other companies, organizations, government or regulatory authorities for fraud protection and credit risk reduction.
* If you are no longer interested in sharing your Personal and Sensitive Information, please e-mail your request at: info@iblfinance.in
* To the Government and other judicial bodies as required under the law in order to
comply with the legal obligations (without the prior permission of customers).
Security
We value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee 100% its absolute security.However, we will do our best to protect and secure your personal information.
Policy Changes
We may update this Privacy Policy to reflect changes to our information practices. You are encouraged to check this privacy policy on a regular basis to be aware of the changes made to it. Continued use of the services and access of the Application shall be deemed to be your acceptance of this privacy policy.
Contact Us
For any query or complaint regarding the privacy and sharing of your customer data, including sharing with third parties, or for suggestions for amendments to this policy, you may contact: Grievance Redressal Officer, Customer Care Department, IBL Finance Private Limited, 1001, World Trade Centre, Nr. Udhna Darwaja, Ring Road, Surat-395002, Gujrat, India. E-mail: info@iblfinance.in, Tel : +91 93281 16200.
- Purpose
The Reserve Bank of India (‘RBI’), vide the Master Direction-Non-Banking Financial Company – Non-Systemically Important Non-Deposit taking Company and Deposit taking Company (Reserve Bank) Directions, 2016 (‘NBFC Master Directions’), as amended from time to time, has directed all NBFCs lay out appropriate internal principles and procedures in determining interest rates, processing and other charges. In this regard, RBI further requires NBFCs to adopt an appropriate interest rate model taking into account relevant factors and to disclose the rate of interest, gradations of risk and rationale for charging different rate of interest. With a view to instituting fair and transparent dealings in the lending business, IBL Finance Private Limited (‘IBL Finance/ Company’) has adopted and put in place the following Interest Rate Policy parallel to the Company’s Fair Practice Code, in accordance with the NBFC Master Directions, as amended and updated from time to time. Keeping in view the NBFC Master Directions, and the good governance practices being followed by the Company, the following internal guidelines, policies, procedures and interest rate model have been adopted by the Company. The Board of Directors of the Company (‘Board’), while fixing interest rates chargeable from the customers shall be guided by this Interest Rate Policy (‘Policy’). In addition to cost factors set out hereunder, the Board or the Committee shall be guided by the market conditions and various rules and regulations, if any, prescribed by the RBI or such other authority from time to time
- Financial facilities covered by the Policy
The Company extends various credit facilities to its customers to cater to the needs of different categories of customers. This Policy shall be applicable to all such financial facilities, as listed below:
- Unsecured Personal Loan
- Meaning of rate of interest
Interest rate shall mean the annualized rate on the credit facilities charged to the borrower by the Company, based on the periodicity of payments, for example, monthly quarterly, etc. The interest rate shall not include the following (the exclusion list is inclusive in nature and shall not be only limited to the components
below):
- Processing costs
- Document charges
- Stamp duty
- External Cost
- Penalties, including late penalties
- Contingent charges
- Prepayment charges
- Third party benefits such as subventions, subsidies etc.
- Any other cost as may be determined by the Committee
- Rates of interest
- The Company may charge either fixed rate or floating rate interest rate for its loan products based on various factors discussed below in this Policy.
- In case of fixed interest rates, the spread would be computed based on product specific and customer specific parameters, as may be determined by the Committee. Fixed interest rates shall not be reset and remain fixed.
- In case of a floating interest rate loan, the base rate and the spread shall be recommended by the Committee and shall be approved by the Board. The interest reset period for floating rate lending would be decided by the Committee from time to time, applying the same decision criteria as considered for fixing interest rates.
- The rate of interest for the same product and tenor availed during the same period by different customers need not be standardized. The final lending rate applicable to each customer will be assessed based on various factors as detailed in this Policy.
- Other factors to be considered
The interest rate applicable to each loan account, within the applicable range, shall be determined on a case-to-case basis, based on evaluation of various factors such as:
- Structure of the deal
- Interest rate trend prevailing in the money market
- Nature of lending, such as secured/unsecured and the associated tenure
- Risk profile of the customer- professional qualification, stability in earnings and employment
- Risk premium keeping in mind the inherent credit and default risk in the product and customer per se arising from relevant customer agreement
- Long term prospects of business with the customer
- Past repayment track record of the customer
- Loan specific costs
- Company’s cost of borrowings
- customer negotiations/deviations
- Industry trends- offerings by competition
- Upfront charges
- Outsourcing cost
- Methodology & Approach for gradation risk
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- The rate of interest shall be arrived at based on the above-mentioned factors.
- The decision to give a loan and the interest rate applicable to each loan account is assessed on a case-to-case basis, based on multiple parameters such as the type of the asset being financed, borrower profile, and repayment capacity, borrower’s other financial commitments, past repayment track record if any, the security for the loan as represented by the underlying assets, loan to value ratio, mode of payment, tenure of the loan, geography (location) of the borrower, end use of the asset etc. Such information is collated based on borrower inputs, credit bureau and field inspection by the company officials.
- The interest rate charged shall be specifically disclosed in the sanction letter/ key fact statement and other relevant communications with the borrowers.
- Other charges
- Besides interest, other financial charges like processing fees, cheque bouncing charges, foreclosure charges/ prepayment penalties, cheque swapping charges, duplicate repayment schedule and legal, repossession and other related matters would be levied by the Company wherever and in the manner considered necessary. Besides the base charges, goods and services tax would be collected at applicable rates from time to time.
- These charges would be decided upon by respective product heads in consultation with operations, finance, and legal.
- However, the Company shall not charge foreclosure charges/ prepayment penalties on any floating rate loan sanctioned for purposes other than business to individual borrowers, with or without co-obligors.
- Penal interest may be charged on any loan remaining unpaid on due dates at such rates as may be determined by the Company provided in the customer loan agreement. These additional or penal interests for different products or facilities would be decided by the respective functional/ product heads. The penal interest charged for late repayment shall be mentioned in bold in the customer loan agreement for drawing the due attention of the customer.
- Disclosures
- The borrower shall be intimated about the loan amount and annualised rate of interest, and if granted through digital lending applications1, annualised percentage rate (‘APR’), at the time of sanction of the loan along with the other
terms of the loan. - The rate of interest and the approach for gradations of risk and rationale for charging different rates of interest to different categories of borrowers shall be disclosed in the application form and communicated explicitly in the sanction letter.
- The rates of interest and the approach for gradation of risks shall also be made available on the website.
- Any change in the interest rate or other charges shall be made prospectively applicable with the concurrence of the borrower, and this condition shall be incorporated in the loan agreement.
- Administration, Amendment and Review of the Policy
The Board shall be responsible for the administration, interpretation, application and review of this Policy. The Board or the Committee, as the case may be, shall also be empowered to bring about necessary changes to this Policy, if so required at any stage at its own discretion or with concurrence. This Policy may be altered/revised as per changes in the market scenario and/or statutory guidelines. This Policy shall be reviewed at least once in a year or when there are amendments in the applicable guidelines.
- Purpose
Recovery is an important aspect of the business of a Non-banking Financial Company (‘NBFC’) so as to ensure that the portfolio remains healthy. Ensuring that collections and recovery of loans are carried out in an effective manner is crucial in ensuring that the NBFC has in place, appropriate recovery mechanisms that adhere to and are in accordance with, fair and ethical practices. The Reserve Bank of India (‘RBI’), vide the Master Direction-Non-Banking Financial Company – Non- Systemically Important Non-Deposit taking Company and Deposit taking Company (Reserve Bank) Directions, 2016 (‘NBFC Master Directions’), as amended from time to time, has directed NBFCs to adopt a ‘Fair Practices Code’ which would, inter alia, include, fair practices with respect to collection and recovery from borrowers of the NBFC.
IBL Finance Private Limited (‘IBL Finance/ Company’) believes in following fair practices with regard to collection of dues and thereby fostering a strong, long term relationship with the customer. Therefore, the Company has adopted and put in place the following Recovery Policy (‘Policy’) parallel to the Company’s Fair Practice Code, in accordance with the NBFC Master Directions, as amended and updated from time to time.
The purpose of the Policy is to lay down practices to be followed by the Company in the matter of recovery of dues in the event of default.
- Manner of collection of dues
The Company would adhere to the following guidelines in the matter of recovery of dues from borrowers –
- The Company shall strictly observe the ethical practices and provisions of Fair Practices Code as formulated by Company and other related stipulations by the RBI with respect to recovery of
- Customers would be ordinarily contacted through the contact details registered with the Company and the Company staff would inform the customer with respect to information regarding their dues;
- Normally the Companies’ representatives will contact the borrower during ordinary business hours between 08:00 hours to 19:00 hours, unless the special circumstances of the borrower’s business or occupation requires the Company to contact at a different time;
- The Company is committed to ensure that all written and verbal communication with its borrowers will be in simple business language and the Company will adopt civil manners of communication for interaction with borrowers;
- The Company shall, while protecting its interest, adopt reasonable and lawful measures to recover its dues from defaulting customers, including use of persuasive methods for the purpose of collection of its dues;
- The Company shall not resort to intimidation of customers, either verbal or physical, or undue harassment by persistently bothering customers at odd hours, use of force and violence, , for recovery of loans.
- In case of any default by the customer, the Company shall serve a notice, through such mode of communication as agreed in the loan agreement, to the customer stating the following:
- the total amount outstanding under loan facility;
- the period within which such outstanding amount shall be paid by the customer;
- the actions that the Company shall take in case of non-repayment within the specified grace
- Upon expiry of the grace period specified in the notice and upon being satisfied that there are no other means of recovering the outstanding amount, the Company shall proceed with the invocation of security interest, if any, or other appropriate legal action shall be initiated by the
- Collection staff/ Recovery agents
While engaging and employing personnel in the recovery function of the Company, the Company shall ensure that adequate training is provided. The recovery personnel should be trained to handle their responsibilities with care and sensitivity with due regard to soliciting customers, hours of calling, privacy of customer information and conveying the correct terms and conditions of the products on offer, etc.
Where the Company is outsourcing its recovery function and engaging recovery agents, Company shall be responsible in training the recovery agents for handling recovery procedures.
While outsourcing the recovery function and engaging recovery agents, the Company shall ensure compliance with the outsourcing guidelines issued by RBI in this regard and the Company shall retain ultimate control of the outsourced activity.
A board approved code of conduct for recovery agents has been put in place, and at the time of appointment of any recovery agent, it is ensured to obtain their undertaking to abide by the code.
The Company shall ensure that the staff and recovery agent shall not resort to intimidation or harassment of any kind, either verbal or physical, against any person in their debt collection efforts, including acts intended to humiliate publicly or intrude upon the privacy of the debtors’ family members, referees and friends, sending inappropriate messages either on mobile or through social media, making threatening and/or anonymous calls, persistently calling the borrower and/ or calling the borrower before 8:00 a.m. and after 7:00 p.m. for recovery of overdue loans, making false and misleading representations, etc.
If at all there is a need for an in-person visit by Company’s personnel or recovery agents to a customer, it shall be done during reasonable hours of the day.
The Company shall be responsible for all the acts of the recovery agents.
- Recovery/ Collection in digital lending cases
For the purpose of recovery/ collection in case of digital loans extended by the Company, the ‘Guidelines on Digital Lending’ issued by RBI on September 02, 2022 would also have to be adhered to.
The Key Fact Statement (‘KFS’) provided to the borrower by the Company will contain the details of the recovery mechanism of the Company.
In case Lending Service Providers (‘LSPs’) are engaged as recovery agents for digital lending cases, the Company shall communicate to the borrower, at the time of sanctioning of the loan and also at the time of passing on the recovery responsibilities to an LSP or change in the LSP responsible for recovery, the details of the LSP acting as recovery agent who is authorised to approach the borrower for recovery.
Additionally, the guidelines laid down by the RBI vide circular dated June 24, 2020 ‘Loans Sourced by NBFCs over Digital Lending Platforms: Adherence to Fair Practices Code and Outsourcing Guidelines’ as also incorporated in the NBFC Master Directions, shall be applicable, in case of collection and recovery of digital loans.
The Company shall impart necessary guidance to LSPs acting as recovery agents to discharge their duties responsibly and ensure that they comply with the extant instructions in this regard.
- Administration, Amendment and Review of the Policy
The Board shall be responsible for the administration, interpretation, application and review of this Policy. The Board or the Committee, as the case may be, shall also be empowered to bring about necessary changes to this Policy, if so required at any stage at its own discretion or with concurrence.
This Policy may be altered/revised as per changes in the market scenario and/or statutory guidelines. This Policy shall be reviewed at least once in a year or when there are amendments in the applicable guidelines.
