privacy-content

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 of User Employees and Onboarded Gig Workers. 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 and You hereby consent to Refyne collecting, processing, using, disclosing, sharing and transferring your Personal Data which may also include sensitive personal information. Without prejudice to any other specific requirement which may be laid out in this Policy, Your use of the Refyne Platform and specifically, Your acceptance of this Policy as aforesaid shall be deemed to be a representation from You that You are above 18 years of age, or possess legal parental or guardian consent, and are fully able and competent to enter into the terms, conditions, obligations, affirmations, representations, and warranties set forth in this Policy, and to abide by and comply with this Policy. This Policy is an electronic record in the form of an electronic contract formed under the Information Technology Act, 2000, and the rules made thereunder and the Digital Personal Data Protection Act, 2023.

In case You do not want to share your Personal Data for use by Refyne as stated in this Policy, You are free to not provide your consent to this Policy and not use the Refyne Platform by deleting your Account.

In case in the future You intend that your Personal Data as collected should not be used or should be erased, You can withdraw your consent as provided in the present Policy, by writing to Refyne to revoke the said consent or deleting your Account, as the case may be. However, it is relevant to note that certain Personal Data may be necessary to make available the Refyne Platform and / or provide You with the Services. Refyne may not be able to provide You with the relevant Products or Services or certain Refyne Platform features if the Personal Data requested is essential for making available the Service and / or the Refyne Platform functionality or features, upon withdrawal of consent.

Refyne reserves with itself rights to modify, change or update this Policy at any time. Continued accessing of the Refyne Platform or use of the Products and Services shall be deemed to be your acceptance of this Policy or amendments thereof.

2. Processing of Information and its Purpose

Refyne collects, processes, uses, discloses, shares and transfers Personal Data, other content, communications, information provided by User Employees / Onboarded Gig Workers, when the Users register on the Refyne Platform, for the purpose of providing the Users with the Products and Services and/or to sell additional products and services which may be offered by Refyne and/or our Financial Partner(s).

Purpose of collecting the information is to enable the User Employees / Onboarded Gig Workers 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 the Employer provides to Refyne which is used to identify You, to provide reference for availing with Products and Services, to contact your references for verification, to reach out to You, to undertake fraud checks, to perform credit risk assessments, to complete your onboarding process and submitting relevant documents and which shall include, without limitation your name, gender, date of birth, age, phone number, photograph, your financial information such as bank account or credit card or debit card or other payment details, your email ID and password, your Employee identification number with the Employer, official email id, your employment history with the Employer, attendance details KYC details (PAN, Aadhar Card, Address Proof, Salary Slip, account details and bank statements, income tax returns etc.),. 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, your mobile device's unique device ID, your Internet Service Provider (ISP) and your Internet Protocol (IP) address.

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 the same. You shall keep updating the Personal Data 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.

Before providing any reference(s) at the time of applying for and/or availing of any Products and Services, You undertake to obtain explicit consent from such reference(s). You shall also inform such person that Refyne or any entity/persons authorized by it, may contact them for conducting your background verification, reach out to You (if you’re not available) and/or to undertake fraud checks on You, to facilitate the Products and Services from its Financial Partners and provide necessary services related to it. If You choose to provide any reference(s) for any of the Products and Services, Refyne shall deem that You have obtained consent from such person (whose reference is given) after disclosing to them the purpose for which their reference is provided. Please note that Refyne or its Financial Partners or its authorized entity/person and/or the Refyne Platform shall be under no duty or obligation to ensure the authenticity or accuracy, or validity of the consent obtained by You from reference(s) or the non-availability of the consent from the references. You agree to indemnify and/or defend Refyne, its Financial Partners and/or its authorized entity/person, against any loss, damages, civil or criminal proceedings and/or any liability which may arise and/or be caused due to breach of this obligation

Refyne may use cookies to monitor and manage your usage of the Refyne Platform including, without limitation, for simplifying your experience when You return to Refyne Platform, like remembering your login ID and certain Personal Data, deliver relevant content based on your preferences, usage patterns and location, tracking etc.

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 does not collect your biometric data. However, Refyne may take a one-time access of Your camera, microphone, location (fine and coarse GPS data), or any other facility for the purpose of onboarding or KYC checks (for such instance of access), after obtaining Your explicit consent, each time you avail the Products and Services available on the Refyne Platform.

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. Details that may be obtained from these devices could include:

Operating system, hardware and software versions, storage space signal quality, battery level, browser type, plugins, name of mobile operator or ISP, language, time zone, IP address, connection speed and installed app data to provide Users with the best credit options.
Network details, camera or photos, beacons, and data from cookies stored on devices to collect Non-Personal Data regarding Users' engagement on the Refyne Platform. Such information will help us in enhancing User experience on the Refyne Platform.
Location-related details including your current location through precise device location, IP addresses, GPS location to provide improved usage and for tracking as provided in the Terms of Use.

The collection of Information for the purposes of the Product and/or Services is done for facilitating Digital Lending Services (services in relation to facilitating the disbursement of lending products/loans offered by Financial Partners) being provided by Refyne in the capacity of a ‘lending services provider’ (LSP) or ‘digital lending application’ (DLA) (both terms as defined under the Reserve Bank of India (Digital Lending) Directions, 2025) of the regulated entities who are registered with the RBI and whose details are available on the Website, the Refyne Platform and application stores (such as Google PlayStore and Apple App Store). Please refer Annexure-I for the list of active Financial Partners on the DLA, along with their respective privacy policies and terms and conditions.

3. Information Usage

Refyne only uses Your Personal Data in accordance with the applicable law, or to provide
You with the Products and Services available on the Refyne Platform, or where Refyne needs
to comply with a legal obligation.

Manage Your Account.
Enable User / customer support
Providing You with access to the Refyne Platform and/or use of the Products and Services.
Send SMS for authenticating operations via One Time Password (OTP) etc.
To facilitate Your KYC.
To facilitate Your application to avail the Products and Services on the Refyne Platform.
To facilitate the provision of Products and Services by our Financial Partners.
Advertising and Marketing
Conduct survey or analysis of your Account.
Develop, test and improve the Refyne Platform, testing and troubleshooting, rectifying glitches, improving navigation and the facilitation of Products and Services.
Data analytics
Legal Compliances and requirements

4. 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:

Sharing with Financial Partners or credit information companies. Information shared by You may be disclosed and shared with the financial partner and/or credit information companies, as the case may be, in order to enable You to avail the Salary / Earned Amount Advance Facility and other Products and Services. Usage of Your Information by such Financial Partners is subject to their privacy policies. We share Information with them to the extent required. We recommend You to go through the privacy policies of such Financial Partners.
Disclosure as required by law or to authorities. your Information may be shared with authorities such as government/statutory/regulatory authorities or under court orders; to establish or exercise legal rights; to defend against legal claims; or as otherwise required by law.
Disclosure to third parties including payment gateways. Refyne may be required to provide, disclose or share Information, that is collected from You to third-party service providers, including payment gateways, to provide the Products and Services to You.
Sharing of Information with prospective acquirers. Information may be required to be disclosed acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity or business of Refyne.
Sharing of information with third-party service providers. We may share your information with third-party service providers who are engaged in the provision of information technology services for fulfilling various aspects of the Refyne Platform and for research and data analytics.
Sharing of information with identity and other information verification providers. We may share your information to identity and other information verification providers to complete identification and information verification processes in accordance with applicable laws.
Sharing of information with Marketing, business development, and sales partners. We may share your information with our marketing, business development and sales partners for the purpose of improving and carrying out marketing or business development activities to provide better services to You through the Refyne Platform.

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:

In the event, You withdraw Your consent, Refyne shall ensure that all the third-parties with whom the data has been shared, delete the same, subject to any regulatory requirements.
Refyne shall enter into a valid contract, with the third-parties, with whom Personal Data may be shared.

Refyne shall not share your Personal Data outside the jurisdiction of India, unless such sharing has been explicitly permitted under the applicable law.

5. 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.

We have internal processes and policies in place to handle information security breaches. Refyne’s incident response team detects, analyses, and responds to information security breaches. In the event of an information security breach, we will take prompt and adequate measures to mitigate the risks to the Personal Data collected or stored by us and take all necessary actions, as required under applicable law, to recover from and respond to such information security breaches. 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.

We restrict access to Your Personal data only to those employees who are required to know such information in order to facilitate provision of the Products and Services on the Refyne Platform to You. We train our employees on all our security procedures.

Reyfne will comply with various technology standards and compliance requirements in relation to cybersecurity, as stipulated by the Reserve Bank of India and other relevant agencies, from time to time.

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.

6. Data Retention

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:

To respond to a question or complaint, or to show whether we gave you fair treatment.
To establish, exercise or defend our legal claims.
To comply with legal rules that apply to us about keeping records or information, in which case we will retain your Personal Data for a minimum of 5 (five) years after your Account has been terminated or longer depending on applicable laws.

7. Your Rights As A Data Subject

Access Rights: You have the right to request access to the following information about Your Personal Data collected:

A summary of the Personal Data which is being processed by Refyne and the processing activities undertaken by Refyne with respect to such Personal Data.
The identities of all other entities with whom the Personal Data has been shared, along with a description of the Personal Data so shared; and
any other information related to the Personal Data and its processing, as may be permitted under applicable law.

Right to correction and erasure of Personal Data: You have the right to correction, completion, updating and erasure of your Personal Data for the processing of which You have previously given consent.
Right to withdrawal of consent: Subject to Section 6 above (Data Retention), You have the right to withdraw your consent provided for the collection and / or processing of your Personal Data at any time, by writing to the Grievance Redressal Officer at the contact details mentioned below. Provided that, such withdrawal shall not affect the legality of processing of the Personal Data based on your consent before such withdrawal. Once You have withdrawn consent to process your Personal Data stored with us, we will stop actively processing your Personal Data but may store it for archival/record keeping purposes in compliance with applicable laws. In such an event, we reserve the right to not allow You to further use the Refyne Platform or use any Products and Services thereunder, without any obligations or liability, whatsoever, whether in contract, tort, law, equity or otherwise, in this regard
Right to grievance redressal: You shall have the right to have readily available means of grievance redressal through the grievance redressal mechanism set up by Refyne, as provided below.
Right to Nominate: You shall have the right to nominate any other individual, who shall, in the event of your death or incapacity shall, exercise your rights as outlined in this Policy.

8. Your Obligations As A Data Subject

You represent and warrant to comply with the following obligations:

Comply with the provisions of all applicable laws as updated from time to time
To ensure not to impersonate another person while providing your Personal Data for a specified purpose
To ensure not to suppress any material information while providing your Personal Data for any document, unique identifier, proof of identity or proof of address issued by the State or any of its instrumentalities
To ensure not to register a false or frivolous grievance or complaint with Refyne or the Data Protection Board (once established); and
To furnish only such information as is verifiably authentic, while exercising the right to correction or erasure under the applicable law.
to update the Personal Data provided, as and when the same changes.

9. 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: Mr. Amit Vikram Pandey

Contact Number: 080-64899999

Email: grievance@refyne.co.in

You may file Your complaint or raise any queries/requests by sending an email to our Grievance Redressal Officer the aforementioned email address. Our Grievance Redressal Officer shall revert to your complaint/query/request within the legally stipulated timelines.

10. Governing Law and Jurisdiction

This Privacy Policy will be governed by and construed in accordance with the laws of India and is subject to the exclusive jurisdiction of Courts at Bengaluru, Karnataka, India.

Last reviewed on: 4th September 2025