Newtap Finance Private Limited (previously known as Parfait Finance & Investments Private Limited)

1. Introduction

This Data Privacy Policy (“Policy”) has been drafted in accordance and compliance with the applicable laws of the land.

2. Purpose of the policy

The purpose of this Data Privacy Policy (“Policy”) is to maintain the privacy of users, members, unregistered visitors, etc. (hereinafter collectively referred to as “users”) and to protect the personal information of the users, provided by them to Newtap Finance Private
Limited (hereinafter referred to as “Newtap ” or “we” or “us”) through Digital Lending. Application (DLA) or our website newtap.in (hereinafter referred to as “Platform”) from time to-time. Newtap through this Policy aims to demonstrate its commitment towards the applicable data privacy laws of India, as amended from time to time.

3. Scope

This policy applies to all functions/departments and processes that deal with collection, processing , storage, transfer, and use of personal data of Newtap employees, customers, visitors, contractors, suppliers, vendors and business associates employees(i.e., past, present, or prospective employees).

4. User Acknowledgement and Consent

User acknowledges that by accessing the Platform or by availing services from Newtap, users expressly consent and confirm to collection, maintenance, usage, handling, and disclosures of user information including the sensitive personal data by Newtap in accordance with this Policy. The user acknowledges that the Platform may contain links to other websites. If a user clicks on a third party link, the user will be directed to that website. Note that these external sites are not operated by us. Therefore, it is strongly advised that users review the privacy
policy of these websites/external links. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. Users acknowledge that they have the option not to provide or agree to the collection of information. If a user chooses not to agree with the Policy, they will not be entitled to avail financial services of Newtap. In case there are any material changes in data that Newtap collects for the purposes of handling, sharing, retention etc., a fresh consent from users will be obtained.

5. Collection of Information

Personal data and information collected directly:

I. Personal Information: Personal information includes any data concerning the personal or material circumstances of an identified or identifiable user, e.g., name, e-mail address, gender, date of birth, postal address, phone number, a unique login name, password,
password validation, marital status, family details, business information and other details shared via application form or via email or via any other medium. It can also include information such as username, account number, password, and any other personally identifiable information. While you can browse some sections of our Platform without being a registered member, as mentioned above, most activities (such as availing of loans and other financial services on the Platform) require registration and for you to provide the above details. We will indicate the mandatory and the optional fields against the information requested from you. You always have the option to not provide your personal
information by choosing not to use a particular service or feature on the Platform.

II. Financial Information: Newtap may have access to the user’s financial information, such as bank account, details regarding the payment instrument, and transaction data pertaining to users collected from partnering merchants, and/or bureau data collected from financial
organizations (including, inter alia and other credit bureaus). Newtap may also have access to users’ payment card details like credit, debit card, and/or internet banking account information, etc., collected via the Platform. The user, by submitting these details explicitly consents to the sharing of its information with the sellers/merchants, third-party payment processors, payment gateways, payment aggregators and other third-party service providers, as may be necessary or required to provide financial services to you.

6. Personal Data from Third Party

I. Credit Reports: Newtap also collects your credit reports and credit data in the event you have applied for a loan / financial facility with us. In this regard, you:

1. Authorize us to request and receive your credit score/report from credit information companies.

2. Further fully understand that the purpose of this credit score/report is to enable us to make informed lending decisions effectively and enable faster processing of credit applications to help provide speedy access to credit through our Platform.

II. Other third parties: Newtap may also work closely with third parties (including, for example, mutual funds registrar and transfer agents, Demat Depositories, account aggregators, business partners, technical sub-contractors, analytics providers, search information providers, etc.) and may lawfully receive information about you from such sources. Such data may be combined with data collected on the portal and such other information as provided in this Policy. In this regard, you:

1. Authorize us to request and receive details of your investment portfolio from such third parties.

2. Further share such information with its third-party lending service providers, payment processors, payment gateways, payment aggregators, and other third-party services providers, as may be necessary or required to provide financial services to you.

III. We may receive your personal information from other third parties, such as digital lending platforms (websites and applications), or other third-party service providers, outsourcing partners of Newtap , (collectively “Third Parties”) and other/ applications, in accordance with the privacy policy of such third-party sites/applications. Such information received from the Third Parties' other websites/platforms/applications at the time of accessing the Website / App may include, and not be limited to, the name, username, profile picture, email address, phone number associated with that Third Party website/ application, any information that has been made provided to that Third Party in connection with that website/ application belonging to you and/ or any information or content of the Third Party The social media website/ application has the right to share with us.

7. Collection of other non-personal information

Newtap automatically tracks certain information about you based upon your relationship with us. We use this information to do research on our users' demographics, interests, and behavior to better understand, protect and serve our users and improve our services. This information is compiled and analyzed on an aggregated basis.

8. Mode of Collection of Information

Newtap may collect user information in a manner that includes the following:

I. Information that the user provides to Newtap by filling in the registration/enrolment/signing up forms on the Platform or on platforms of third-party lending service providers of Newtap, and for KYC purposes.

II. Information that the user provides when the user writes directly to Newtap by way of email, messages, etc.

III. Information that the user provides to Newtap over the telephone.

IV. Information that the users provide by completing surveys, a survey, poll, sweepstakes, contest, or promotion scheme.

V. Information that the user provides merely by accessing/navigating the Platform.

VI. Information collected by Newtap through independent third-party sources, like merchants, financial organizations, business partners, governmental or regulatory agencies, third parties, and credit bureaus.

9. Use of user information

By submitting user information to Newtap, users expressly acknowledge and consent to the use of such information in a manner specified under this Policy. The user’s right to access, review data and correct/amend data shall be as per existing privacy laws. User information can be used for various purposes including but not limited to the following:

i. To verify user identity;

ii. To facilitate user with usage of platform or avail services from us;

iii. To obtain credit reports and evaluate your creditworthiness for availing the loan /facility from Newtap.

iv. For extension of loan and financial services to the user by Newtap

v. To ensure compliance with all legal obligations of Newtap, vis-à- vis Know-your Customer, Prevention of Money Laundering etc.

vi. For fraud prevention and detection;

vii. To send user surveys and marketing communications that Newtap believes may be of user interest;

viii. To analyze, conduct internal reviews, surveys and understand the users, improve the content and features of the platform;

ix. To diagnose technical problems, provide support and help users in addressing and troubleshooting problems;

x. To send and receive communications, show advertisements, notifications and make promotional offers;

xi. To prepare, review and file reports as per applicable laws;

xii. To contact users regarding third party services and offers;

xiii. To understand user preferences, requirements;

xiv. To permit user to participate in interactive features offered through the Platform;

xv. To improve the content and protect the integrity of the Platform;

xvi. To increase / improve the products / services offered by the lender on the Platform;

xvii. To ensure compliance with all applicable laws. 

10. Disclosure of information

We will share your information with third parties in India, or outside India, to facilitate provisioning of services by us to you only in such manner as described below:

i. We may share your information to our third-party service providers for providing the services as detailed under the Terms & Conditions;

ii. We may share your information with our third-party partners in order to conduct data analysis in order to serve you better and provide services on our platform;

iii. We may share your information, without prior notice, if required under any law or if we are under a duty to do so in order to comply with any legal obligation or an order from the government and/or a statutory authority, or in order to enforce or apply our terms of use or assign such information in the course of corporate divestitures, mergers, or to protect the rights, property, or safety of us, our users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;

iv. We may also share the data / information with our technology service providers, lending service providers, digital lending applications and other outsourcing partners to perform credit and know your customer checks to facilitate a loan for the user as per applicable laws;

v. We may share your data with our affiliates and/or group companies for data processing and analysis. We may share your information from MFC (Mutual Fund Central) or RTAs (Registrar & Transfer Agents) with our lending service providers;

vii. We and our affiliates may share your information with another business entity should we (or our assets) merge with, or be acquired by that business entity, or reorganization, amalgamation, restructuring of business for continuity of business;

viii. Newtap employs subcontractors/technology service providers to offer Credit Products. Some of your data/data concerning Credit Products may be shared with these entities and/or stored in their systems (Kindly refer: Newtap Service Provider List)

ix. Newtap will ensure that such third parties maintain the same level of data protection that is adhered to by the body corporate as provided for under this Policy.

11. Data protection, retention, storage and breach notification

Pursuant to applicable data protection laws, Newtap endeavours to protect sensitive personal information and data of the users against accidental or unlawful destruction or loss, alteration, unauthorized disclosure or access (both physical and logical) These precautions shall include technical, physical and organizational security measures as defined in our Information Security policy. You further understand and agree that repayment of a loan / financial facility does not automatically rescind the consents you have provided to us under the Privacy Policy nor does deletion of your account with the Platform. We shall store your information and/or data for such period as may be required by Newtap to:

(i) enforce its legal rights and obligations against you;

(ii) to ensure compliance with its obligations and responsibilities under applicable laws in the capacity of a lender regulated by the Reserve Bank of India. Once your Information and/or data is no longer required, it will be disposed of securely. We store and process your personal information on cloud servers. We use reasonable safeguards to preserve the integrity and security of your information against loss, theft, unauthorized access, disclosure, reproduction, use or amendment. To achieve the same, we use reasonable security practices and procedures as mandated under applicable laws for the protection of your information. We have robust procedures in place to handle data breaches securely and efficiently. Newtap maintains a comprehensive incident response plan to be executed in the event of a data security incident or breach which is in compliance with the RBI’s Digital Lending Directions, 2025. In the unlikely event of a security incident affecting user data, we take immediate action to contain the issue, assess the impact, and notify the Regulators, Partners, and affected users as required under applicable laws. Necessary remedial measures to address the cause are implemented to prevent recurrence.

12. User rights

Newtap shall ensure that the following rights of users are upheld in case the user opts to exercise any of the following rights except in cases where these rights are conflicting with explicit requests/ guidance from regulatory or legal authorities pursuant to applicable data protection laws and regulation. Users have following rights:

i. Right to Access: Users can access their personal data held by Newtap , including its source, processing purpose, and recipients.

ii. Right to Correct: Users can request corrections to their personal data if it is inaccurate or incomplete.

iii. Right to Erasure: Users can request their personal data be deleted if it’s no longer needed or if the user withdraw consent.

iv. Right to Restrict Processing: Users can limit the processing of their data, such as by unsubscribing from communications.

v. Right to Data Portability: Users can obtain their personal data in a structured format to transfer it to another service.

vi. Right to Object: Users can object to certain data processing activities, including for certain purposes.

vii. Right to Withdraw Consent: Users can withdraw their consent for data processing at any time.

viii. Right to Nominate: Users have the right to nominate another individual to exercise their rights in the event of death or incapacity of the user.

ix. Right to Grievance Redressal: Users have the right to accessible channels for addressing grievances about any actions or failures by Newtap regarding their personal data or rights.

13. Monitoring and enforcement

Newtap, shall monitor the regulatory environment to be compliant with the requirements of the law. Any changes and updates to the regulation or law shall be reflected in the organization's Data Privacy Policy. The Information Security team shall ensure that policies and principles comply with relevant privacy and data protection laws and regulations. Information Security team shall provide oversight for all third-party relationships to ensure that authorized third parties are notified and agree to comply with Newtap's Data Privacy Policy. In addition to compliance with Newtap's data privacy policies, the organization shall strive to abide by the privacy laws in the country of its business and operations.

14. Changes to privacy policy

In the event Newtap modifies this Privacy Policy, the same will be updated on the Platform. In case of any changes to the Policy, the users will be notified by means of a notice on Platform prior to the change becoming effective. The users are encouraged to periodically review this page for the latest information on Newtap’s privacy practices.