PRIVACY POLICY
COMPANY INTRODUCTION
The PaisaGhur online digital lending platform (“PaisaGhur”) is owned and operated by QUARK
FINANCIALS PAKISTAN (PRIVATE) LIMITED, a company incorporated under the
provisions of the Companies Act, 2017, holding CUIN 0233558 (hereinafter referred to as the
“Company”) and licensed as a Non-Banking Finance Company with license no. SECP/LRD/126/QFPPL/2023. The Company is
engaged in the business of providing Nano-loans
to its customers in Pakistan through the PaisaGhur App on Google play (which terms includes
the PaisaGhur mobile application (the “Application/App”) only.
PRIVACY POLICY
By visiting the 'PaisaGhur' mobile application and availing the services
provided by us or dealing in sensitive personal Data and information you expressly consent to PaisaGhur App (“we”
or “our” or “us”) to use and disclosure of your personal information in accordance with this Privacy Policy. This
Privacy Policy is incorporated into and subject to the Terms of Use of the App. For the purpose of this Privacy
Policy, the users of the Services may be customer/ consumers, or any other persons using Services or accessing our
Mobile Application.
If you do not agree to this Policy or any part of it, please do not use or access our Mobile Application.
COLLECTION OF PERSONALLY IDENTIFIABLE INFORMATION
When you use our application/website, whether that is Website or our app, we store and collect your information
which is
provided by you from time to time by explicitly seeking permission from YOU to get the required information. Our
primary goal in doing so is to provide you a safe, efficient, smooth and customized experience and services. This
allows us to provide services and features that meet your needs and to customize our Mobile Application to make
your experience safer and easier and to improve our services. Most importantly, we only collect personal
information from you that we consider necessary for achieving the aforementioned purpose. In general, you can
browse the Website or app without telling us who you are or revealing personal information about yourself.
However, to create an account on the Website or App you must provide us with certain basic information required to
provide customized services. The information we collect from you while signing up includes:
h) Guarantor's Contact details
l) Password and other registration information (such as the security questions and
answers we already have on your account), personal description and photograph.
Where possible we indicate the mandatory and optional fields. You always have the
option to not provide your personal information by choosing not to use a particular service or feature on the
Mobile Application. We also collect other identifiable information (your payment card details and other
transaction histories on the PaisaGhur) from you when you set up a free account with us as further detailed below.
While you can browse some sections of our PaisaGhur without being a registered number as mentioned above, certain
activities (such as availing of loans from the third party lenders on PaisaGhur) requires registration and for you
to provide the above mentioned details. The PaisaGhur shall clearly display the information it is collecting from
you and you have the option to not provide such personal information at any given time. However, this will limit
the services provided to you on the PaisaGhur.
MOBILE NUMBER AND EMAIL ADDRESS
When you sign up with us, we collect your mobile number and address to uniquely
identify you. This helps us ensures that no unauthorized device or person is acting on your behalf.
CAMERA
[PaisaGhur] requires access to your device’s camera for the following purposes:
a) To scan CNIC documents
c) To capture a live photo for security verification of your loan account
The photos are used solely for loan approval and will not access your devices gallery or stored photos. You
consent will be obtained each time you grant camera access and you may revoke this permission at any time through
your device's settings. All Data collected will be stored securely and used in compliance with Data protection
laws. The App will not have access to your photo gallery.
LOCATION
PaisaGhur will collect location information from your account. By doing this, PaisaGhur
will reduce the financial risk associated with your account. User location helps PaisaGhur to locate and verify
the address provided by you.
After PaisaGhur has accessed the location information, you possess the prerogative to deactivate the geo location
feature on your device at you discretion. Please rest assured that we will never divulge your location Data with
any third party unless sanctioned by the exceptions delineated in this policy, or as required by applicable law.
PHONE
PaisaGhur will collect user hardware information, OS and version, unique device
identifier (IMEI Number), wifi and mobile network information and profile information, SDK version, SIM serial and
SIM Slot. This information is used to prevent fraud by uniquely identifying the devices and restricting
unauthorized devices to act on your behalf.
The collection of information by apps and the use of that information depend on how you
manage the privacy controls on your device. When you install an application, we store the collected information
along with a unique identifier linked to the device you are using. When you download and install our App we
collect information from the device and explicitly seek your permission to obtain the necessary information from
it.
We gather information from your device to provide automatic updates and enhanced
security to prevent unauthorized account access. Additionally, this information offers us valuable insights into
your identity as a device owner and your device’s behavior enabling us to improve our services and deliver a more
customized user experience. Further, Ad ID information is utilized for fraud prevention, security and compliance
purposes. For instance, we use this information to monitor failed login attempts, helping us identify potential
fraudulent activities.
REFERENCE CONTACTS
Borrowers are only required to enter the contact details of their reference contacts
during the loan application process. This allows us to verify the customer's and reference contacts identities via
phone/text message, prevent fraud and track collections. We upload this contact information to our servers in an
encrypted format within a secure network environment.
COLLABORATOR
The SDK we use to connect with Deeplink third-party services is distributed across
various social networks, including Google and Facebook. It discerns the attribution source of user channels and
communicates the identity of each channel. Neither deep link nor PaisaGhur accesses or uses any information from
user's private accounts
DATA RETENTION AND DELETION
The information provided by the uploaded CNIC and facial photos is only used for
detecting and verifying the authenticity of your identity as well as confirming whether the facial photo on the
current operating app matches the CNIC, ensuring they belong to the same individual.
The above mentioned Data, shall be stored for a maximum of one year from the date of acquisition. If the customer
wants to delete the Data they can send a request to the customer service at the following email:
support@paisaghur.com and we can manually delete the Data within 3-5 business days.
DATA SECURITY
All PaisaGhur transactions are protected by using the AES-256 encryption algorithm to
ensure its security. The Data will be transferred and uploaded over a secure connection (https). All Data will be
stored within Pakistan cloud server provided by Cyber Internet Services (Private) Limited.
OTHER NON-PERSONAL INFORMATION
In addition to collection of personally identifiable information aforesaid, we also collect your Internet Protocol
(IP) address and the URL used by you to connect to the internet, etc. This information may include the URL that
you just came from, (whether this URL is on our website or not) which URL you go next to (whether this URL is on
our website or not), your computer browser information, and your IP address. We use this information to do
internal 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. Cookies are
small data files that a website stores on your computer. We will use Cookies on our websites similar to other
lending websites/apps and online marketplaces websites/apps. Most websites will permit you to decline Cookies but
if you choose to do this it may affect service on some parts of our website. We retain this information as
necessary to resolve disputes, provide customer support and trouble shoot problems as permitted by law. The
Company may use Cookies to manage our users' sessions and to store preferences, tracking information, and language
selection. Cookies may be used whether customer's register with us or not.
If you send us personal correspondence, such as emails or letters, or if other users or third parties send us
correspondence about your activities about your activities or postings on the Website, we collect such information
in a file specific to you.
We will not use Cookies for any purposes not states in this privacy policy. You can clear all the Cookies stored
on your computer and most webs provide the option of blocking Cookies. However, by doing so, you have to change
the user setting every time you visit our website.
USE AND DISCLOSURE OF YOUR PERSONAL AND OTHER INFORMATION
We access, store and use the information we collect from PaisaGhur to provide our
services, to research and develop new ones. We use personal data to provide the services you request, to customize
your user experience and improve our services. To the extent we intend to use to your personal information to
market any product to you, we will provide you the ability to opt-out of such uses. We use your personal
information to:
c) Help promote a safe service
e) Measure consumer interest and satisfaction in our products and services
f) Inform you about online and offline offers, products, services and updates
g) Customize your experience
h) Detect and protect us against suspicious or illegal activity , fraud and other
criminal activity
i) Enforce our terms and conditions
j) Improvement of our services and as otherwise described to you at the time of
collection of. In our efforts to continually improve our product and service offerings we collect and analyze
demographic and profile data about our users' activity on our Website.
USE OF YOUR DEVICE INFORMATION
We use the information provided by you in the following ways:
a) To establish identity and verify the same
b) Monitor, improve and administer our
c) Provide our service i.e. perform credit profiling for the purposes of facilitating
loans to you
d) Design and offer customized products and services offered by our third party
partners
e) Analyse how the website is used, diagnose service or technical problems and maintain
security
f) Send communication notifications, information regarding the products or services
requested by you or process queries and applications that you have made on the Website/App
g) Manage our relationship with you and inform you about other products and services we
think you might find of some use
h) Conduct Data Analysis in order to improve the services / products provided to the
user
i) Use the User information in order to comply with the country law and regulations
j) To conduct identity for our third party lenders based on the information shared by
the User
k) Uses the information in other ways permitted by law to enable you to take services
from our lending partners
The above data shall be stored for 1 year from the date of acquisition. If the customer
wants to delete the data they can send a request to the customer service at the following
email:support@paisaghur.com and we can manually delete the Data within 3-5 business days.
DISCLOSURE TO THIRD PARTIES
We may disclose some or all of the data we collect from you when you download or use
the PaisaGhur platform to connect to mobile wallet providers, credit bureaus, or other partner financial
institutions. We may disclose your personal information to any member of our group, which means our subsidiaries,
our ultimate holding company and its subsidiaries. Please note that disclosure will be limited to parties with
whom you have an agreement and undertaking, per policy. We will share Your information with third parties only in
such manner as described below:
a) We disclose and share your information with the Service Providers
b) We may also use a third party payments service provider or payments processing
company to process payments and re payments, transfer money to your Operative Account or any other user account,
process other payments, and to provide additional products and services and may disclose your information to such
third party payments service provider
c) We may disclose your personal information without prior notice, if we are under a
duty to do so to comply with any legal obligation or any order from any government and/or statutory body 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.
d) We shall use your data for the purpose of compiling statistics relating to our user
base or financial products or services and may disclose such information to any third party for such purposes
provided that such information will always be anonymous.
e) 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 re organization, amalgamation,
restructuring of business for continuing of business. Should such a transaction occur than any business entity (or
the new combined entity) receiving any such information from us shall be bound by this Policy with respect to your
information.
f) We may use other third party companies to monitor site traffic, which may in some
instances, store customer information. Where we use another organization, we still control your personal
information and we have strict controls in place to make sure its properly protected.
g) By using PaisaGhur you hereby grant your consent to the Company to share/disclose
your
personal information.
h) In order to enforce any other terms and other agreements or to investigate potential
breaches; report defaulters to any credit bureau or for the purpose of publishing statistics relating to the use
of PaisaGhur Platform, in which case all information will be aggregated and made anonymous.
i. To the concerned third parties in connection with the Services
ii. With the governmental authorities, quasigo vernmental authorities, judicial
authorities, and quasi-judicial authorities, in accordance with the applicable laws in Pakistan. In case we use or
disclose your information for any purpose not specified above, we will take your explicit consent.
CHANGES IN THIS PRIVACY POLICY
[PaisaGhur] reserves the right to change, modify, add or remove portions of this
Privacy Policy
at any time for any reason. In case, any changes are made in the Privacy Policy, we shall update
the same on the Website and email to users. Once posted, those changes are effective
immediately, unless stated otherwise. We encourage you to periodically review this page for the
latest information on our privacy practices. Continued access or use of the Services constitutes
your acceptance of the changes and the amended policy Privacy Policy.
ACCESSING YOUR PERSONAL INFORMATION
To the extent required by applicable laws , you have the right to access your personal
information collected and the details of your treatment, as well as to rectify them if they are inaccurate ir
cancel their use through a written request addressed to the following email address support@paisaghur.com or by
submitting a letter within the office facilities of the Company during office hours on working days , said
requirements will be attended on priority basis. Please note that deleting or withdrawing information may affect
the services we provide to you . If there is any change in personal information made by you, you must provide
supporting documents related to the change of personal information for verification by the company.
YOUR PRIVACY CONTROLS
You have certain choices regarding the information we collect and how it is used:
a) Device Level Settings: Your Device may have controls that may determine what
information we collect. For example, you can modify permissions on your Android device for access to Camera or
audio permissions.
b) Delete your entire App Account
c) You can also request to remove content from our servers based on applicable law or
by writing to your Grievance Officer.
SECURITY PRECAUTIONS
The Website/App intends to protect your personal information and to maintain its
accuracy as confirmed by you. 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.
PaisaGhur has stringent security measures in place to protect the loss, misuse and alteration of information under
control. We endeavor to safeguard and ensure the security of the information provided by you. We use Secure Socket
Layers (SSL) based encryption, for the transmission of information, which is currently the required level of
encryption in Pakistan as per the law. 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.
An ISMS is a framework of policies and procedures that includes all legal, physical and technical controls
involved in an organizations information risk management processes. We work hard to protect from unauthorized
access, alteration, disclosure or destruction of information we hold, including:
a) We use encryption to keep your data private while in transit
b) We offer security feature like an OTP verification to help you protect your account
c) We review our information collection, storage and processing practices, including
physical security measures to prevent unauthorized access to our systems
d) We restrict access to personal information to our employees, contractors, and agents
who need that information to process it. Anyone with this access is subject to strict contractual confidentiality
obligations and may be disciplined or terminated if they fail to meet these obligations
e) Compliance and Cooperation with Regulations and applicable laws
f) We regularly review this privacy policy and make sure that we process your
information in ways that comply with it
g) Data transfers us or our Affiliates maintain your information on servers. Data
protection laws vary among countries, with some providing more protection than others.
When we receive formal written complaints, we respond by contacting the person who made
the complaint. We work with the appropriate regulatory authorities, including local data protection authorities,
to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.
LINKS TO OTHER SITES
Our Website links to other websites that may collect personally identifiable
information about you. We are not responsible for the privacy practices or the content of those linked websites.
With this policy we're only addressing the disclosure and use of the data collected by us. If you visit any
websites through the links on the Website, please ensure you go through the privacy policies of each of those
websites. Their data collection practices, and policies might be different from this Policy and we do not have any
control over any of their policies neither do we have any liability in this regard.
PROTECTION OF MINORS
We place great value on the protection of minors' personal information. As required by applicable laws and
regulations, any user under the age of 18 should be banned to use our service. As the parent or statutory guardian
of a minor, it is your responsibility to prohibit your child from using our service. Otherwise, all legal
consequences are borne by yourself.
DISPUTES
With respect to any disputes related to this Privacy Policy, including but not limited to any provisions related
to indemnification, limitation of liability relating to damages, choice of law and dispute resolution forum, we
ask you to first submit any such complaints directly to us the relevant customer services desk or helpline.
YOUR CONSENT
By using the Website/App and/or by providing your information, you consent to the
collection and use of the information you disclose on the Website in accordance with this Privacy Policy including
but not limited to your consent for collecting, using, sharing, and disclosing your information as per this
Privacy Policy. If we decide to make any changes to our Privacy Policy, we will first obtain your explicit consent
before implementing such changes. Once your consent is obtained, the updated Privacy Policy will be posted on this
page, ensuring that you are always informed about the nature of the information we collect, how we use it, and the
circumstances under which it may be disclosed.
You may revoke or restrict your consent at any time, subject to the terms of the
Privacy Policy and the General Terms.
Please connect with us via:
Customer Care Service: +92 3709053061 Email: support@paisaghur.com
Business Hours: Monday to Sunday 09:00 - 18:00 (holidays excluded)
Company Name: Quark Financials Pakistan (Private) Limited
Principle Business: Micro/Nano Lending
Status of Company: NBFC (Investment Finance Service)
License No. SECP/LRD/126/QFPPL/2023
License Date of Issue: October 24, 2024
Address: Lower Ground Floor, Plot No. 69, Qatar Arcade, Street 34, Sector G-10/1, I & T Center, Islamabad.