Privacy Policy
With effect from [•] This Privacy Policy [the “Privacy Policy”] is
created and published in accordance with Rule 3 (1) of the Information
Technology (Intermediaries Guidelines) Rules, 2011, which requires the
publishing of Privacy Policies and Terms of Use for website access or
usage. This Privacy Policy regulates your use of the Website
https://minko.app/, Mobile Application
https://play.google.com/store/apps/details?id=com.app.minko&hl=en_IN&gl=US
as well as email communications received from [.], and text messages
received from [.] [collectively, referred to as the “Platform/MINKO”].
Minko Application is developed by Minko Platforms Private Limited, a
company incorporated under the Companies Act, 2013 with its registered
office at 263/1, Karapur Tisk, Vithalapur, Karapur, Sanquelim, North
Goa- 403505, Goa, India (“the Company/We”). We value the users of our
website or application (“Minko/Platform”) and the information provided
by them. We understand that the Users might be concerned about the
collection, use and disclosure of the Personal Information, viz.
personally identifiable information, that we collect when you access
Minko. For the aforementioned purpose, the Privacy Policy describes
the collection, processing and storage of information we receive from
you. It is pertinent to note that by using Minko you are accepting the
practices described in this Privacy Policy. Also, by using Minko you
are giving consent to the use of your Personal Information by us in
accordance with the terms set out in this Privacy Policy.
DEFINITIONS
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“Account(s)” refers to your profile(s) (created after undergoing the
Registration Process) by which you are able to create and share
information, personal messages, communications and other content.
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“Cookies” are small files stored on your device (computer or mobile
device) while browsing through the Platform or Application.
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“Fee(s)” means the charges as prescribed in the Platform and as
payable by you through the payment gateways available on the
Platform for availing the Services available on the Platform.
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“End-User(s)” refers to person or his/her representative(s) or
affiliate(s), who has/ have an Account (after undergoing the
Registration Process) with the Platform want to make an Account
through the Platform to avail the Services provided therein.
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“Personal Information” as defined under the Information Technology
(Reasonable Security Practices and Procedures and Sensitive Personal
Data or Information) Rules, 2011 [the “SPI Rules”] means 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 person.
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“Sensitive Personal Data or Information” as defined under Rule 3 of
the Information Technology (Reasonable Security Practices and
Procedures and Sensitive Personal Data or Information) Rules, 2011
[the “SPI Rules”].
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“Registration Process” means the process which a User undergoes
while registering himself/ herself/ themselves on the Platform
thereby creating an Account in accordance with the process mentioned
in the Terms of Use available at https://minko.app/terms-
conditions.html.
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“Service(s)” means and includes enabling short term credit for
retailers and buyers against their invoice issued by the
distributor/seller/anchor via NBFC partners.
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“Usage Data” is data collected automatically either generated by the
use of Service or from Service infrastructure itself (for example,
the duration of a page visit).
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“You”, “Your”, “User” or “Users” refers to any individual,
organisation, association or to his/her/ their representatives or
affiliates, who utilises or visits the Platform and includes
“End-User(s)”.
WHAT INFORMATION DOES MINKO COLLECTS FROM YOU?
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Personal Information- Generally, you can visit and browse the
Platform without disclosing the personal information. However, to
fully use the Services provided by the Company, via the Platform,
you are required to undergo the Registration Process as provided in
the Terms of Use available at
https://minko.app/terms-conditions.html. Minko collects sensitive
and personal information which you provide to us during the
registration process, which includes but is not limited to your
name, date of birth, gender, resident status, mailing address, phone
number (primary and alternate), email address, credit card number,
Aadhar verification, pan number, business name, business address,
GST number, tan number, business registration certificate, bank
account details.
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Non-Personal Information- Minko also collects non-personal
information from you, which includes but not limited to your browser
type, URL of the previous website you visited, ISP, operating system
and you IP Address. It is to clarify that non-personal information
cannot be readily used to personally identify you.
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Location Data-Minko may use and store information about your
location if you provide us permission for the same. Minko uses this
data to provide features of our service, to improve and customize
our services, and provide efficient service to you. Kindly note that
you have an option to enable or disable location services while
using MINKO, at any time by way of your device settings.
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Tracking Cookies Data- We use data collection devices such as
Cookies and similar technologies to track the activity on Minko and
we hold certain information. Please note that Cookies are files with
a small amount of data which may include an anonymous unique
identifier. You can decline the use of Cookies in your browser.
Since each browser is different therefore you have to check with the
browser to learn how to manage Cookies. However, if you opt to not
accept Cookies, you may not be able to avail some portions of the
Services offered by MINKO.
PURPOSE OF COLLECTION OF INFORMATION
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We may use the Personal Information provided by you for the
following purposes:
- for the purpose of providing you the Services;
- for the purpose of improving the quality of the Services;
- for marketing and promotional purposes;
- for the purpose of transactional communications;
- for the purpose of financial transactions;
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for the purpose of debugging customer support related issues;
- for the purpose of receiving feedbacks from the User(s);
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for the purpose of responding to summons, court orders or other
legal obligations;
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for the purpose of research and generating statistical analysis;
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for the purpose as mentioned under the Information Technology
Act, 2000 and the rules thereunder.
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Minko or any person/organisation acting on behalf of Minko shall not
be responsible for the authenticity and accuracy of the Personal
Information and/or the Sensitive Personal Data or Information
provided by you.
STORAGE AND RETENTION OF DATA
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Minko stores Personal Information and/or Sensitive Personal Data or
Information within India and retains it only for as long as it is
necessary to provide our Services and to comply with our legal
obligations, resolve disputes, and enforce our policies.
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Retention period will be determined taking into account the type of
data that is collected and the purpose for which it is collected,
bearing in mind the requirements applicable to the situation and the
need to destroy outdated, unused data at the earliest reasonable
time.
OBLIGATIONS OF THE USER(S) FOR THE PERSONAL INFORMATION AND/OR THE
SENSITIVE PERSONAL DATA OR INFORMATION
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By using Minko app/web, user gives their consent that Minko could
collect, disclose, share, and use user's information in accordance
with the terms of this privacy policy, also user consented to be
bound by the terms and conditions of this Privacy Policy.
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If case where user does not wish/wants Minko to collect, disclose,
share and use users’ information, including but not limited to any
personal information (as defined below), user may choose not to
register for an account or terminate their account with Minko in
accordance with the applicable Terms and Conditions available at the
App/web.
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You hereby consent to the collection and use of the Personal
Information and/or the Sensitive Personal Data or Information,
provided by you to Minko, for any of the purposes stated herein.
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You agree and understand that all the information provided to Minko
by you, including Personal Information and/or the Sensitive Personal
Data or Information, is voluntary.
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For creating the Account, you are required to provide Personal
Information and/or the Sensitive Personal Data or Information such
as the Username, User ID, email address, country, ZIP/postal code,
age, phone number, and valid financial account information.
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You agree and understand that Minko is not liable for the
authenticity of the Personal Information and/or the Sensitive
Personal Data or Information provided/ supplied by you.
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You are responsible for the accuracy and correctness of the
information that you submit to Minko.
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If you intend to deregister your Account or request that your
information no longer be used, you can contact Minko by sending an
email addressed to collections@minko.app. Upon receiving such
request, Minko shall not keep such information in its databases
beyond the required time.
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After the withdrawal of consent, or cancellation of Account, Minko
may discontinue or may not be able in a position to provide the
Services to such User(s).
DISCLOSURE OF PERSONAL INFORMATION AND/OR THE SENSITIVE PERSONAL DATA
OR INFORMATION
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The following is applicable to all the User(s):
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You confirm and agree that Minko does not sell or share any
Personal Information about you with other people/ organisation
except to provide the Services under the Terms of Use or this
Privacy Policy.
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Minko shall only disclose the Personal Information and/or the
Sensitive Personal Data or Information only to the extent as
will be necessary to provide its Services as under:
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Minko may require you to pay a certain amount of Fee via a
credit card, debit card or through other online payment
gateways, viz. Decentro, Castler, Cashfree, for the Services
rendered by Minko. You may opt for Minko to collect and
store such your credit card number and/or other financial
information such as bank account numbers, in a digitally
encrypted format, for ease of payment processes and future
references.
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When you visit the Platform, Minko will automatically
receive the IP address of your computer, operating system
and type of web browser that is being used. This will help
Minko to analyse the overall trends which will help the
Platform in improving its Services.
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Minko, via the Platform, uses temporary cookies to store
certain data and for the purpose of research and
development, and for administration purposes. These cookies
do not store any of your Personal Information and/or the
Sensitive personal data or information.
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Minko has no control over the third-party websites that may
be displayed as search results or links from within the
Services. These third-party websites may place their own
cookies or other files on your computer, collect data or
solicit personal information from you, for which Minko shall
not be liable.
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Other parties if so required by any law at the time being in
force and in compliance of Minko's legal obligation.
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Minko shall disclose the Personal Information and/or the
Sensitive personal data or information to Government agency
if so mandated under the law in force at the relevant time.
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The following information collected will not be shared with any
third parties or disclosed to any person other than as required
by law; Sensitive Personal Data or Information of any person
being the password, financial information such as Bank account
or credit card or debit card or other payment instrument
details, sexual orientation or any other sensitive personal
information not essential for the continued use of the Website.
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We may share Personal Information with our other corporate and
/or associate entities and affiliates to help detect and prevent
identity theft, fraud and other potentially illegal acts and
cyber security incidents; correlate related or multiple accounts
to prevent abuse of our services; and to facilitate joint or
co-branded services that you request where such services are
provided by more than one associate entity. Those entities and
affiliates may not market to you as a result of such sharing
unless you explicitly opt-in.
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We may disclose Personal Information if required to do so by law
or in the good faith belief that such disclosure is reasonably
necessary to respond to summons, court orders, or other legal
process. We may disclose Personal Information to law enforcement
offices, third party rights owners, or others in the good faith
and belief that such disclosure is reasonably necessary to:
enforce our Terms of Use or Privacy Policy; respond to claims
that an advertisement, posting or other content violates the
rights of a third party; or protect the rights, property or
personal safety of our users or the general public.
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We give access of your Personal Information only to those
personnel's/officials who are authorised in this behalf and the
third-parties who are hired by them to perform administrative
services. We do not guarantee that your information will be kept
confidential by these parties and we will not liable in any
manner for the loss of confidentiality by them.
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Minko has implemented best market practices and security
policies, rules and technical measures to protect the Personal
Data/ Information of the User(s) from unauthorised access,
improper use, disclosure of data, unauthorised modification and
damage or accidental loss.
TRANSFER AND SECURITY OF PERSONAL INFORMATION AND/OR SENSITIVE
PERSONAL DATA OR INFORMATION
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Your Personal Information and/or the Sensitive Personal Data or
Information is maintained by Minko in its secured/ encrypted
database. Minko may also keep the records of electronic
communications with you through the Platform for the limited purpose
as stated herein the Privacy Policy and for customer support,
research and development, for administrative purpose.
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Your Personal Information and/or the Sensitive Personal Data or
Information may be transferred to and maintained on a secured/
encrypted database outside your State and the laws might differ
accordingly.
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You agree and understand that the Personal Information and/or the
Sensitive Personal Data or Information provided by you are shared
with the employees of the Company who are authorised in this behalf
and on need-to-know basis for the purpose of rendering Services to
you.
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You understand that all the employees of the Company who have access
to such Personal Information and/or the Sensitive Personal Data or
Information are obligated to keep the same confidential. Minko is
committed towards maintaining your Personal Information and/or the
Sensitive Personal Data or Information secret and confidential.
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Minko may transfer the Personal Information and/or the Sensitive
Personal Data or Information to any third party for providing better
Services on behalf of Minko. The third party shall also maintain and
ensure protection and confidentiality of the Personal Information
and/or the Sensitive personal data or information of such User(s).
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If Minko or its subsidiaries, if any, are involved in a merger,
acquisition or asset sale, your Personal Information and/or the
Sensitive Personal Data or Information may be transferred in
accordance with law and also in accordance the agreements executed
for such merger(s)/ acquisition(s)/ asset sale(s).
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Minko takes all reasonable precautions to protect your data (whether
online or offline) and your Personal Information and/or the
Sensitive Personal Data or Information. You understand that no one,
except the End-User(s) will have access to End-Users' passwords for
its Account.
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Minko shall not be liable to indemnify you for any loss suffered by
it due to such unauthorized use of your Account and the password
thereof.
AMENDMENRS IN PRIVACY POLICY
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The Company may update the Privacy Policy from time to time. Minko
will notify you of any changes by posting the new Privacy Policy on
the website available at https://minko.app/Minko retains the right
to change, modify or terminate the terms of this Privacy Policy, or
any portion of this Privacy Policy, at any time by publishing such
changes on the Website. The amended Privacy Policy would be
effective as on the date of change, which Minko would post on the
Website, and it shall be binding upon you from such date. If you do
not agree to any of the terms and conditions in the amended Policy,
you may discontinue from using the service available on Minko
immediately.
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You are advised to review this Privacy Policy periodically for any
changes. Use of information Minko collects, is subject to the
Privacy Policy in effect at the time such information is used. Your
continued use of the Services following the posting of changes to
this Privacy Policy will constitute your consent and acceptance of
those changes.
RESTRICTIONS ON USAGE
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You are not permitted to host, display, upload, modify, publish,
transmit, update, share or distribute any information that:
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belongs to another person and over which you have no right upon;
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is defamatory, obscene, pornographic, grossly harmful,
harassing, blasphemous, defamatory, obscene, paedophilic,
libellous, invading another's privacy, including bodily privacy,
insulting or harassing on the basis of gender, hateful,
libellous, racially or ethnically objectionable, disparaging,
relating to or encouraging money laundering or gambling, or
otherwise unlawful in any way;
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harms minors in any way; infringes on the rights of minor;
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infringes on any patent, trademark, copyright, or other
proprietary rights; violates any current law;
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includes software viruses or any other computer code, files, or
programmes designed to disrupt, damage, or limit the functioning
of any computer resource;
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is patently false and untrue, and is written or published in any
form, with the intent to mislead or harass a person, entity or
agency for financial gain or to cause any injury to any person.
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The Company reserves the right to delete any content and/or remove
any non- compliant information from the Platform that violates any
of the foregoing criteria.
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The Company also reserves its right to terminate the access to any
User(s) immediately in case of non-compliance with the Terms of Use
and Privacy Policy.
PERMISSIONS
Certain permissions are being sought by Minko /digital platform/APP,
from the consumer at the event of downloading the application,
registration or requesting for loan.
- Camera Access - to capture the individual image, check the liveliness and authentication of the applicant. The incident may be termed as “Selfie”
- Location - This area specific permission helps understand and filter location which are marked as negative/ sensitive for lending.
- Microphone- to complete the process of onboarding
CONSENT TO THIS POLICY
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You voluntarily acknowledge that this Privacy Policy is a part of
the Terms of Use of the Platform. You agree that visiting the
Platform or utilising the Services of the Platform you signify your
consent to this Privacy Policy. Your visit to the Website and use of
the Services is subject to this Privacy Policy and the Terms of Use.
JURISDICTION
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This Agreement is governed by Indian law, which includes, but is not
limited to, the following:
- The Indian Contract Act, 1872;
- The (Indian) Information Technology Act, 2000;
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The (Indian) Information Technology (Reasonable Security
Practices and Procedures and Sensitive Personal Information)
Rules, 2011;
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The (Indian) Information Technology (Intermediaries Guidelines)
Rules, 2011;and
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The Information Technology (Intermediary Guidelines and Digital
Media Ethics Code) Rules, 2021.
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Minko was created in the Indian state of Goa, India. The laws of the
State of Goa will apply to this Agreement. You consent to the
jurisdiction and venue of the courts in Goa, India in connection
with any action, suit, process, or claim arising under or by reason
of this Privacy Policy by using Minko.
GRIEVANCE CELL
If you have any question regarding this Privacy Policy, access or
usage of computer resource, and/or to register any complaint, you can
approach the Grievance Officer appointed by Minko. You may reach out
the Grievance Officer vide an email addressed to
collections@minko.app, the official email-id of the Grievance Officer.
The Grievance Officer and Minko shall make reasonable and prompt
efforts to resolve your issue. The details of the Grievance Officer
are mentioned herein below:
Name : Rishu Mathur
Address: 263/1, Karapur Tisk,
Vithalpur, Sanquelim, North Goa-403505
Phone:
91-9699700762
Email: collections@minko.app
Availability:
In case your complaint remains unaddressed for a period of one month,
you may appeal to the Customer Education and Protection Department of
Reserve Bank of India.