Privacy Policy

1. Introduction

Refyne Tech Private limited (hereinafter referred to as “Refyne” or "the Company”), through its Website, i.e., https://www.refyne.co.in/ and Mobile Application called "Refyne” runs an employee financial wellness platform (“Refyne Platform”) that allows the employee users to track their salary and enables them to withdraw on credit, the earned amount of salary at any point of time at an agreed transaction fees which credit is extended by Financial Partners with whom Refyne has arrangements.

The terms used in the Privacy Policy ("Policy”) have the meaning as defined in the Terms of Use. The   present policy lays down how Refyne collects, uses, processes, discloses, shares and transfers   Personal Data and other data of users of the Refyne Platform (“You” or “User”) . This Policy must be   read in consonance with the Terms of Use.

By using or accessing the Refyne Platform or opening an Account on the Refyne Platform, You agree   to accept the terms contained in the present Policy. This Policy is an electronic record in the form of an   electronic contract and is created in accordance with (i) Information Technology Act, 2000 and rules   made thereunder; (ii) Digital Personal Data Protection Act, 2023 and rules made thereunder; (iii)   Reserve Bank of India (Non-Banking Financial Companies – Credit Facilities) Directions, 2025; and (iv) other applicable laws, regulations and rules.

In case You do not wish to agree to the terms of this Privacy Policy, You may feel free not to use the Refyne Platform.

Refyne reserves with itself rights to modify, change or update this Policy at any time. In the event Refyne makes any changes in this Policy, the same will be communicated to You. It is hereby suggested that You carefully read and understand the Policy before agreeing to the terms and conditions set forth herein.

2. Collection of Consent

The Company collects your consent by giving to You a notice containing the following information:  

This notice shall be in a plain and easy to understand language and shall be available to You in English or in any of the languages mentioned in the Eighth Schedule of the Constitution of India.

3. Processing of Information and its Purpose

Refyne collects, processes, uses, discloses, shares and transfers Personal Data, other content,   communications, information provided by You or on your behalf, your Data Fiduciary(ies) or Data   Processors when the Users register on the Refyne Platform, for the purpose of providing the User with   the Products and Services.

Purpose of collecting the information is to enable the User to access and avail the Products and Services available on the Refyne Platform.

For the purpose of this Policy, the term "Personal Data” shall mean any information You or on your   behalf your Data Fiduciary(ies) or Data Processors provides to Refyne which is used to identify You, to reach out to You, to undertake fraud checks, to perform credit risk assessments, to complete your   onboarding process and submitting relevant documents with your Data Fiduciary(ies) or Data   Processors For the purpose of this Policy, the term "Non-Personal Data” shall mean information that   does not specifically identify an individual but includes information from You such as the type of internet   browser You use, mobile device or computer You use, your preferences on the Platform, and your Internet Service Provider (ISP)

Personal Data and Non-Personal Information together is referred to as "Information”. Refyne may   collect Information from You when You open an Account or fill the Application Form, when You use the   Products and Services, when You participate in surveys conducted by Refyne, when You interact with   the customer care team, or when You carry out transactions on the Refyne Platform. You specifically   undertake and warrant the accuracy and truthfulness of the Personal Data You share and agree that   You shall be solely responsible for any and all data submitted by You. You shall keep updating the   Information provided, in the event such information changes. You can change or update your Personal Data, by sending an email to the grievance redressal officer, whose details are mentioned below.

You agree to indemnify Refyne, against all losses, damages, claims, penalties, costs arising out of the   inaccuracy of the Personal Data provided. Refyne may collect details about your use of the Refyne   Platform and/or Products and Service, such as the features used, any activity carried out and the   frequency/duration/time thereof, the actions taken etc.

Refyne may be required to collect and combine details from and about the mobile phones, computers,   tablets, and other electronic devices that You may use to access the Refyne Platform.

Information that may be obtained when You use Platform could include:

The data collected for the purposes of KYC shall be further processed by our partnered Non-Banking Financial Company (NBFC) for credit underwriting purposes and to ensure compliance with all applicable laws and regulatory requirements.

4. Information Usage

Refyne may use your Information to:

5. Data Storage and Security

All data collected from you is stored exclusively on secure servers located within the territory of India. Refyne maintains a strict audit trail of all data flows to ensure compliance with these localization mandates.

6. Information – How It May Be Shared

Refyne may disclose or share your Information, which includes your Personal Data, with the following   persons to enable providing of Products and Services:

If You send us personal correspondence, such as emails or letters, or if other Users or third parties   send us correspondence about your activities on the Refyne Platform, we may collect and store   such information for providing services and for record keeping purposes.

Refyne shall ensure the following, with respect to the Personal Data shared with third-parties:

Refyne shall not share/process your Information outside the jurisdiction of India, unless such sharing/processing has been explicitly permitted under the applicable law. List of third parties with whom Information may be shared:

7. Protection Of Information

Our servers are located within the territory of India, where your data is stored securely.

The Platform has reasonable security measures as per the Information Technology Act, 2000 in place to protect the loss or misuse of the information under our control. 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. However, You agree that the same cannot be foolproof since no security system is impassable and accordingly Refyne cannot and does not commit or guarantee that the Information may be absolutely free from invasion or breach.

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, as per the applicable law. Refyne stores and processes User Personal Data in a hosted environment secured within Virtual Private Cloud setup on Public Cloud viz Amazon AWS.

We blend security at multiple steps within our products with the state-of-the-art technology to ensure our systems maintain strong security measures and the overall data and privacy security design allow us to defend our systems ranging from low hanging issue up to sophisticated attacks. Please note that we or our Financial Partners or any person authorized by us will not ask You to share any sensitive data or information such as account/login/passwords/financial information (bank details, OTPs etc) and other sensitive personal information via email/telephone/SMS/link. Please do not share such information to any person even if such persons claims to be the authorized representative of us and/or any of our partners. However, transacting over the internet has inherent risks which can only be avoided by You following security practices yourself, such as not revealing account/login/passwords/financial information such as bank details, OTPs and other sensitive personal information to any other person. In the event You suspect that your account/personal information has/may have been compromised or You receive any suspicious call, SMS, link, email requesting your sensitive personal information, You may reach out to our grievance officer and inform him of the same.

The Platform may contain links to third party applications/websites that may collect Personal Data about You. In the event You access such third party applications/websites, please be aware that the privacy policy of such third party shall be applicable on the information collected from such applications/websites. Please refer to the privacy policies of such third parties before sharing any data with them. Refyne shall not be liable or responsible for any breach of security or disclosure of your Information by or for any actions or inactions of the financial partner or any other third party that receives your Information. 

You are solely responsible for maintaining the confidentiality of your username and password and Refyne would, in no circumstances be liable or responsible for any breach in this regard by You.

In the event of becoming aware of any cyber security incident or breach by Refyne or any third-party to whom your Personal Data has been shared, Refyne shall duly intimate You and the relevant authorities, in accordance with the Applicable law.

8. How We Handle Data Breaches

We take the security of your information seriously. In the unlikely event of a personal data breach, we have strict protocols in place to protect your rights and keep you informed  If we become aware of a breach involving your personal data, we will notify you promptly without delay. This notification will be sent through your user account or the contact details you have registered with us. To ensure you stay informed, we will provide:

In compliance with the law, we will also notify the Data Protection Board of India immediately following a breach. The intimation will include a description of the breach, including its nature, extent, timing, location of occurrence and likely impact. Within 72 hours or within such longer period as the Board may   allow, we will provide the Board with a comprehensive report pertaining to the breach which will include detailed information in respect to such breach such as facts related to the events, circumstances and reasons leading to the breach, the remedial measures we are implementing to prevent it from happening again, any findings regarding the person who caused such breach, report regarding the intimations given to affected Data Principals and any other information as required by the Board in this   regard.

9. Data Retention and Destruction Protocol

We will keep your Personal Data as long as you are a borrower and/or in the event where you have availed any of the Products and Services through the Refyne Platform. We may keep your information after you stop being a borrower/customer of the Products and Services. The reasons we may do this are:

We will comply with the following procedure for destruction and disposal of Your Personal Data and other information:

10. Your Rights As A Data Principal

11. Your Obligations As A Data Subject

You represent and warrant to comply with the following obligations:

12. Mechanism For Grievance Redressal

In accordance with the Information Technology Act, 2000. and the rules made thereunder, and the Digital Personal Data Protection Act, 2023, and the rules thereunder (once implemented) the contact details for raising grievances, if any are provided below:

Address: Prestige Pegasus, Sarjapur - Marathahalli Rd, Ambalipura, Haralur, Karnataka 560103

Name: Goutham R.

Contact Number: 7795501555

Email: grievance@refyne.co.in

13. Governing Law and Jurisdiction