Privacy Policy

BY ACCESSING OR USING THE PLATFORM OR BY OTHERWISE GIVING US YOUR INFORMATION, YOU WILL BE DEEMED TO HAVE READ, UNDERSTOOD AND AGREED TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND AGREE TO BE BOUND BY THE PRIVACY POLICY. YOU HEREBY CONSENT TO OUR COLLECTION, USE, SHARING, PROCESSING AND DISCLOSURE OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.

"Platform" shall mean this internet based electronic website platform (www.suninvestments.in) and/or an application, website and/or web page (including but not limited to any web app, marketing landing page(s) and/or iOS/Android app or any other app that the User may be using to access/communicate with SIPL), owned and/or operated, directly or indirectly, by SIPL.

By accessing or using this Platform, you agree to be bound by this Privacy Policy and other applicable policies, including the Terms of Use ("Agreements"). This Privacy Policy together with Our Terms of Use, a copy of which is at Terms of Use ("Terms of Use"), and the other Agreements, together with all other notices, disclaimers, guidelines appearing on the Platform from time to time, constitute the entire agreement upon which You are allowed to access and use the Platform.

This Privacy Policy governs the usage of information and the ways in which you can protect your privacy. This Privacy Policy is created and published in pursuant to (i) Section 43A of the Information Technology Act, 2000; (ii) Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011; and (iii) Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 ("SPDI Rules"), is applicable to all customers of SIPL, users of the Platform and visitors of the Platform ("User").

In accordance with the SPDI Rules, any sensitive personal data or information of a person means and includes such personal information about that person relating to: (a) passwords; (b) financial information such as bank accounts, credit and debit card details or other payment instrument details; (c) physical, physiological and mental health condition; (d) sexual orientation; (e) medical records and history; (f) biometric information; and (g) information received by body corporates under lawful contract or otherwise.

Certain information provided by Users may allow for personal identification of the Users, including email addresses, telephone numbers and other contact information.

It may be noted that any information that is freely available in the public domain or accessible under the Right to Information Act, 2005, or any other law will not be regarded as sensitive personal data or information, or as personally identifiable information.

For the purpose of this Privacy Policy, wherever the context so requires: (a) "We", "Us", "Our", or "SIPL" means SIPL or any of its subsidiaries or Affiliates; and (b) "User" or "You" or "Your" means a legal person who is given access to use the Platform for the purpose of availing Product or Services on the Platform;

Your Information

1.1. The Platform is owned and operated by Sun Investments Private Limited ("SIPL"), whose registered office is at 4th Floor, JSW Centre Bandra Kurla Complex Bandra (East), Mumbai - 400051.

1.2 SIPL collects the following types of information about you when you use the Platform: Account Information, Demographic Information, Financial Information, Behavioural Information, Indirect Information (collectively, "Information") and User Information.

1.3 In order to use the Platform or avail any Products and Services (defined hereunder) offered by SIPL, you may be required to provide us with Your details including but not limited to Your name, address, third party sign-in information shared on other websites (such as Facebook, Google, Twitter, or Pinterest), contact number and email address, Aadhaar number / VID number, biometric information and/or One Time Pin (OTP) data, know-your-customer (KYC) documents, GST registrations and related information, information regarding the services you browse and email communication by/with us such as enquiries, orders, and transaction-related information, disputes or complaints ("Account Information").

1.4 "Products and Services" means the range of financial products and services offered through our Platform, including but not limited to loan products and any ancillary services related to managing, applying for, or servicing those loans.

1.5 "Personal Information" is defined under the SPDI Rules to mean any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available to a body corporate, is capable of identifying such a person. Should any of the information defined below be classified as Personal Information, you hereby agree that we may collect, use, share, process and/or disclose the Personal Information for the purposes as set out in this Privacy Policy.

1.6 We may collect from you, information that is not unique to you, in the sense that it refers to selected population characteristics, such as Your postal code, IP location, URL and occupation ("Demographic Information").

1.7 To avail and use the Products and Services, you may be required to share financial information (as defined under applicable law) including without limitation bank account details, bank statement details, financial and transactional information to process Your application or provide you Products and Services, annual reports (if applicable), GST data, transactional data with service providers and other financiers, credit report obtained from any/ all of the recognised credit bureaus, credit and repayment history etc. (collectively referred to as "Financial Information"). If Financial Information collected from the Users’ by any party other than SIPL, the verification of the Financial Information shall be accomplished only by the User through a process of authentication in which SIPL shall have no role to play.

1.8 We also collect information regarding how you use the Platform. This includes the areas of the Platform that you visit, and information about Your computer hardware and software including Your IP address, browser and operating system type, IMEI number and MAC address of the computer/device from where the Platform was accessed, domain names, access times, locations which may also include global positioning system coordinates or similar information regarding the location of the device using which the you have visited or used the Platform, Your previous transactions including the pricing details, transaction information and payment and browsing history ("Behavioural Information").

1.9 Your use of certain third-party services on the Platform requires us to collect such information as is considered necessary for that purpose ("Indirect Information").

1.10 We also collect Your details including but not limited to information regarding Your transactions on the Platform (including purchase and financing history). We also collect details including Your information such as passwords, financial information such as bank account information or credit card or debit card or other payment instrument details, any other items of "sensitive personal data or information" as such term is defined under the SPDI Rules; identification code of Your communication device which you use to access the Platform or otherwise deal with SIPL, any other Information that You provide during Your registration process, if any, on the Platform and any other information that You voluntarily choose to provide to us ("User Information").

1.11 SIPL may keep records of telephone calls received from and made to Users for the purpose of administration of Products and Services, research and development, training, business intelligence, business development, or for User administration. SIPL may share the telephone records with third parties when required by law or when required to provide or facilitate the User with the Products and Services.

1.12 SIPL may choose to conduct contests and surveys to collect relevant information about the Users’ preferences. These surveys and contests are optional and if the User chooses to respond, his/her/its responses will be kept anonymous. The demographic information that the User provides while availing or signing-up for the Products and Services and through any surveys or contests is used to help SIPL improve its services to meet the needs and preferences of Users.

1.13 SIPL has implemented security policies, rules and technical measures, as required under applicable law including firewalls, transport layer security and other physical and electronic security measures to protect the Financial Information and Personal Information that it has under its control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. It is expressly stated that SIPL shall not be responsible for any breach of security or for any action of any third parties that receive Users’ personal data or events that are beyond the reasonable control of SIPL including, acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, etc.

1.14 SIPL or its Affiliates, parent company, group companies, subsidiaries, associates, affiliates, suppliers, vendors, sister concerns, service providers and service partners and other third parties (collectively referred to as "Other Parties") may merge with or be acquired by another business entity. In such an event, SIPL and the Other Parties may be required to transfer the Personal Information to such merging or acquiring party, as the case may be. While sharing such Personal Information with the acquiring or merging entity, as the case may be, SIPL and the Other Parties shall make reasonable endeavours to ensure that the User’s Personal Information is duly protected by the acquiring or merging entity, as the case may be, by undertaking security measures prescribed under applicable laws.

1.15 SIPL may also disclose or transfer the personal and other information provided by Users, to any third party as a part of reorganization or a sale of the assets, division or transfer of a part or whole of the company. Any third party to which SIPL transfers or sells its assets will have the right to continue to use the personal and other information that Users provide to SIPL.

1.16 SIPL may be required to disclose Personal Information or Financial Information to governmental institutions or authorities when such disclosure is requisitioned under any law or judicial decree or when SIPL, in its sole discretion, deems it necessary in order to protect its rights or the rights of others, to prevent harm to persons or property, to fight fraud and credit risk, or to enforce or apply the Terms of Use.

1.17 The User’s use of Products and Services, visit to and/or use of the Platform and any dispute over privacy is subject to this Privacy Policy. SIPL may update this Privacy Policy at any time, with or without advance notice. SIPL shall not be required to notify the Users of any changes made to this Privacy Policy. It is Your responsibility, in such cases, to review the terms of this Privacy Policy from time to time.

1.18 The User consents to SIPL reproducing / publishing all testimonials and reviews given by the User (whether on the Platform, social media platforms, or in any other manner whatsoever) in relation to SIPL or any of its Products and Services, together with the User’s name and location on such page and in such position as SIPL may determine in its sole discretion. The User agrees that SIPL may edit the testimonials and reviews provided by the User and reproduce / publish such edited or paraphrased versions of the testimonials and reviews on the Platform. If the User has any concerns with the reproduction / publication of any testimonial or review provided by the User on the Platform, the User may contact SIPL at corporate.compliance1@jsw.in

1.19 If You use the Products and Services or the Platform on behalf of someone else (such as Your company, partnership or trust). you represent that you are authorised by such entity to accept this Privacy Policy on such entity’s behalf, and consent on behalf of such entity to our collection, use, sharing, processing and disclosure of such entity’s information as described in this Privacy Policy.

1.20 All the information provided to SIPL by a User, including Information, is voluntary. The User has the right to request the withdrawal of his/her/its consent at any time, in accordance with the terms of this Privacy Policy and the Terms of Use. It is the User’s duty to ensure strict caution while giving out any Information about himself/herself/itself or his/her family members in use of any of the Products and Services. SIPL does not endorse the content, messages or information found in any Products and Services and therefore, SIPL specifically disclaims any liability with regard to the Products and Services and any actions resulting from the User’s participation in any Products and Services. As a condition to use the Products and Services, you as a User agree to waive any claims against SIPL relating to the same, and to the extent such waiver may be ineffective, you agree to release any claims against SIPL relating to the same.

Use of Information

2.1 We may use Your Information for the following purposes:

  1. To identify the User, to understand his/her/its needs and resolve disputes, if any;
  2. To set up, manage and offer Products and Services and to enhance the Products and Services to meet the User’s requirements;
  3. To provide ongoing Service;
  4. To create Your account and verify Your identity and access privileges;
  5. To conduct KYC compliance processes as required under applicable laws;
  6. To carry credit checks, screening, or due diligence checks as required under applicable laws;
  7. To meet legal and regulatory requirements;
  8. To conduct data analysis/ analytics;
  9. To authenticate a transaction request;
  10. To resolve technical issues and troubleshoot problems;
  11. To aid SIPL in collecting monies from Users, including through recovery agents appointed by SIPL in this regard;
  12. To facilitate financing services;
  13. To facilitate repayments;
  14. To keep Users appraised of SIPL’s (or third parties’) promotions and offers;
  15. To enforce SIPL’s terms;
  16. To generate aggregated data, either directly or through partners and/ or group companies of SIPL to prepare insights to enable SIPL to understand Your preferences, patterns and trends with a view to learning more about Your preferences or other characteristics;
  17. To customize User experience;
  18. To advertise SIPL’s and SIPL’s partners/ anchors/ affiliates services;
  19. To detect and protect SIPL from error, fraud and other criminal activities;
  20. To investigate, prevent, and take action against illegal or suspected fraud or money laundering activities and conduct forensic audits;
  21. To address Your grievances, feedback, or inquiries;
  22. To ensure compliance with applicable laws;
  23. Other reasons which, prior to being put into effect, shall be communicated to the Users through an update carried out to this Privacy Policy.

2.2 Additionally, we use Demographic Information, Behavioural and Indirect Information of the Users collectively, such as what areas Users visit most frequently and what Products and Services Users access the most. Such data is used anonymously and in the aggregate. This information helps Us determine what is most beneficial for the Users.

2.3 While SIPL shall make reasonable endeavours to ensure that the User’s Personal Information and Financial Information is duly protected by undertaking security measures prescribed under applicable laws, the User is strongly advised to exercise discretion while providing Personal Information or Financial Information to SIPL and any third party payment gateways/financiers while using the Products and Services given that the Internet is susceptible to security breaches.

Disclosure of the Information

3.1 We may disclose Your Information to third parties, including without limitation, anchors, duly appointed partners / service providers, co-lenders, group companies, associates and affiliates of SIPL, and other third parties who are authorised by us to perform functions on our behalf.

3.2 We may disclose and transfer Your Information or User Information to a third party who acquires the business units, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of the assets; or

3.3 We may disclose Your Information if legally required.

3.4 Subject to applicable law, We may, at our sole discretion, transfer Information to any other body corporate (as defined under the Information Technology Act, 2000) that ensures at least the same level of data protection as is provided by us under the terms hereof in accordance with applicable law. By using the Products and Services or the Platform, you accept the terms hereof and you hereby consent to the storage and processing of information in any of the above locations.

Changes to your Information

4.1 You may review, correct, update, change Your Account Information or User Information on the Platform. You may request us to delete Your Account Information or User Information, which we would do, unless we must keep certain information for legal purposes.

4.2 We reserve the right to verify and authenticate Your identity and Your Account Information to ensure the accurate processing of Your Products and Services. Access to or correction, updating or deletion of Your Account Information may be denied or limited by us if it would violate another person’s rights and/or is not otherwise permitted by applicable law.

Security of your Information

5.1 We endeavour to maintain physical, technical and procedural safeguards that are appropriate to protect Your Information and User Information against loss, misuse, copying, damage or modification and unauthorized access or disclosure. Some of the security measures adopted by Us are:

  1. We review our information collection, usage, storage, processing and disclosure practices, including physical security measures, to guard against unauthorized access to systems;
  2. b) We restrict access to Your Information to our employees, agents and partners who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations, and may be disciplined or whose relationship with Us may terminate if they fail to meet these obligations.

5.2 All SIPL employees and data processors, who have access to and are associated with the processing of Personal Information or Financial Information provided by Users are obliged to respect the confidentiality of every User’s Personal Information or Financial Information.

5.3 All information collected from the Users by SIPL is maintained in electronic form on servers and/or cloud systems and shall be accessible by certain employees of SIPL. The User information may also be converted to physical form from time to time. Regardless of the manner of storage, SIPL shall make commercially reasonable endeavours to ensure that the User information is rendered confidential, and will disclose User information only in accordance with the terms of this Privacy Policy.

5.4 If You wish to cancel Your account or request that We no longer use Your information to provide You and Products and Services, contact Us at compliance@jswonefinance.in. After a period of time, your data may be anonymized and aggregated, and then may be held by us as long as necessary for us to provide our Products Services effectively, but our use of the anonymized data will be solely for analytic purposes. Please note that Your withdrawal of consent or cancellation of account may result in us not being able to provide you with our Products and Services.

5.5 The Platform may use temporary cookies to store certain data. SIPL does not store personally identifiable information in the cookies. Information collected by SIPL, by any means whatsoever, that does not personally identify the User as an individual (such as patterns of utilization described above) is exclusively owned by SIPL and may be used by SIPL and third-party service providers for technical administration of the Platform, user administration, research, development, and other purposes. Additionally, SIPL may sell or otherwise transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to Other Parties.

5.6 A User may set or amend his/her/its web browsers to delete or disable cookies. If a User chooses to disable cookies on his/her/its computer, mobile telecommunication device, or any such device being used to access the Platform, it may impair, degrade or restrict access to certain areas of the Platform. Merely closing the web browser should ordinarily clear all temporary cookies installed by SIPL. However, Users are encouraged to use the "clear cookies" functionality of their browsers to ensure deletion, as SIPL cannot guarantee, predict or provide for the behaviour of the equipment of all the Users of the Platform.

Opt-Out Policy

7.1 You agree and consent to receive all communications, including but not limited to text messaging services or over-the-top communication services (including inter alia WhatsApp, Facebook Messenger, Telegram, Google, Signal, JioChat), at the mobile number provided by you, or any such number which may be provided to SIPL from time to time, even if such mobile number is registered under DND/NCPR list under the Telecom Regulatory Authority of India (TRAI) regulations. Notwithstanding Your registration with the National Do Not Call Registry (in the fully or partly blocked category under National Customer Preference Register set up by TRAI), you hereby express Your interest and accord informed consent to receive communications (including commercial communications) in relation to SIPL's services. You further confirm that no communication to you from SIPL or on behalf of SIPL shall be construed as "unsolicited commercial communication" under Regulation 2(bw) of the Telecom Commercial Communications Customer Preference Regulations, 2018 and you have specifically opted to receive communications in this regard on the mobile number provided by you or any such number which may be provided to SIPL from time to time. And for that purpose, you further authorise SIPL to share/disclose the information to any third party service provider or any affiliates, group companies, their authorised agents or third party service providers of SIPL.

7.2 All Users may opt-out of receiving non-essential, promotional, or marketing-related communication from SIPL. You can address the said opt-out requests to the Compliance Officer. If a User wishes to remove his/her/its contact information from SIPL’s call/email lists and newsletters, the User can contact the Compliance Officer in this regard. SIPL however reserves the right to limit accessibility to the Platform and related services provided by it based on availability of information from the Users.

Contact Information

Users can access, modify, correct and eliminate the data about him/her/it which has been collected pursuant to his/her/its decision to become a User. If you believe that Your rights are being infringed or you have any complaints or concerns, including in relation to the information shared by the User with SIPL on the Platform, you may reach out to our compliance officer through electronic mode in the following manner:
Kind Attention: Compliance Officer
Address: 4th Floor, JSW Centre Bandra Kurla Complex Bandra (East), Mumbai - 400051
Email: corporate.compliance1@jsw.in
We respond expeditiously to rights owners and their agents who communicate their concerns about any alleged infringement in the manner provided under this Privacy Policy.

Applicable Law and Dispute Resolution

This Privacy Policy shall be construed and governed by the laws of India without giving effect to conflict of law principles and all disputes arising out of these terms shall be referred to the relevant court of competent jurisdiction in India.

RBI Disclaimer

  1. a) "Reserve Bank of India neither accepts any responsibility nor guarantees the present position as to the financial soundness of the company or for the correctness of any of the statements or representations made or opinions expressed by the company and for discharge of any liability by the company."
  2. b) "Neither there is any provision in law to keep, nor does the company keep any part of the deposits with the Reserve Bank of India and by issuing a Certificate of Registration to the company, the Reserve Bank of India, neither accepts any responsibility nor guarantees the payment of the deposits to any depositor or any person who has lent any sum to the company."
  • © .  Sun Investments Pvt. Ltd. All Rights Reserved.