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MASTER TECHNOLOGY FINTECH SERVICES PRIVATE LIMITED

DIGITAL LENDING
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Privacy Policy

This Privacy Policy describes our practices regarding the collection, use, security, and disclosure of your personal and financial data when you use the MoMo Rupee platform.

Compliant with the Information Technology Act (2000), RBI Guidelines on Digital Lending, and the Digital Personal Data Protection Act (DPDPA, 2023).

Welcome to MoMo Rupee (referred to as the "Platform", "We", "Us", or "Our"). This Privacy Policy describes our practices regarding the collection, use, security, and disclosure of your personal and financial data. This document is maintained in strict compliance with the Information Technology Act (2000), the Reserve Bank of India (RBI) Guidelines on Digital Lending, and the Digital Personal Data Protection Act (DPDPA, 2023).

By installing, registering, or interacting with the Platform, you acknowledge that you have read and understood the terms of this Privacy Policy. If you do not agree with these practices, please discontinue use of the platform.

1. Data Storage, Localization, and Security

Data Localization: In compliance with RBI directives, all user information—including personal, technical, and transactional data—is stored and processed exclusively on secure cloud servers physically located within the territorial boundaries of India.

Security Implementations: Data transmission across the platform is secured using standard Secure Sockets Layer (SSL)/Transport Layer Security (TLS) encryption protocols. Access to user data internally is restricted via role-based access control models.

Data Retention: We retain your data only for the duration necessary to fulfill the services requested or to satisfy legal and regulatory mandates, such as the Prevention of Money Laundering Act (PMLA). Upon the expiration of these regulatory periods, data is permanently deleted.

2. Operational Framework & Lending Partners

Platform Role: MoMo Rupee functions strictly as a technology interface and a Lending Service Provider (LSP). The Platform does not possess a banking or Non-Banking Financial Company (NBFC) license and does not extend credit directly from its own capital.

Regulated Entity Engagement: All credit facilities available via the platform are underwritten, approved, and disbursed exclusively by our authorized lending partner:

Official Lending Partner (RE): Vaishali Securities Limited (An RBI-registered NBFC).

Eligibility Framework: To utilize these services, you must be a resident citizen of India, at least 18 years of age, and possess the legal capacity to contract under the Indian Contract Act, 1872.

3. Categories of Information Collected

We operate under the principle of data minimization, limiting our collection to data necessary for credit evaluation and identity verification.

User Profile & Verification Data:

  • Identity Details: Full Name, Date of Birth, Gender, and Marital Status.
  • Contact Details: Current residential address, active mobile number, and email address.
  • Regulatory Identification: Aadhaar and PAN card details for compliance with mandatory Know Your Customer (KYC) requirements.
  • Financial Attributes: Bank account number and IFSC details to enable disbursement and repayment routing.
  • Network Information: IP address, carrier network details, and connection type (Wi-Fi or cellular).

Application Permissions:

Access to specific device features requires explicit, user-initiated consent. These permissions are tied to structural steps in the application process:

Camera

We need camera access to capture your ID documents and perform liveness detection for account security and anti-fraud purposes. All images are encrypted and used exclusively for identity verification.

Microphone

We request microphone permission to support voice operations and facilitate the KYC process. You may choose to enable it or not, and we will not record any audio when you are not interacting.

Location

We collect approximate device location to verify you are within our service scope in India and assess location-related credit risks. Location data is only accessed during the application.

App List

We access the list of installed apps to evaluate your credit status, prevent fraud and offer a proper credit limit. Only app names and types are collected. All data is transmitted via encryption to protect your privacy.

Device Information

We collect device details including hardware model, OS version, unique identifier and mobile network data to verify device identity, block unauthorized access and identity theft, and secure your accounts and transactions.

4. Purpose of Processing

Your collected information is processed solely for identified lawful objectives:

  • Application Underwriting: Sharing relevant data points with the partner NBFC to facilitate credit assessments.
  • Risk & Credit Evaluation: Querying registered credit bureaus through authorized channels to verify credit history.
  • Regulatory Alignment: Execution of Anti-Money Laundering (AML) and KYC checks required by financial authorities.
  • Operational Communication: Transmission of One-Time Passwords (OTPs), regulatory disclosures, transaction confirmations, and statutory payment schedules.

5. Data Disclosure & Third-Party Sharing

Data is disclosed to third parties only under the following defined parameters:

  • To the Partner NBFC: Complete identity, KYC, and financial profiles are transferred to Vaishali Securities Limited as required for credit adjudication.
  • Service Subcontractors: Limited data may be accessible to secure infrastructure vendors handling transactional SMS dispatch, identity e-verification (Aadhaar eSign), or payment processing. These vendors operate under formal Non-Disclosure Agreements (NDAs).
  • Statutory Obligations: Information will be provided to law enforcement agencies, judicial courts, or regulatory bodies (such as the RBI) when commanded by a legal mandate.
  • Corporate Events: In the event of an asset assignment, merger, or organizational restructuring, data assets may be transferred to the successor entity subject to this privacy framework.

6. Data Subject Rights & Consent Management

Withdrawal of Consent: Users retain the right to withdraw their consent for data processing at any point. However, if there is an active financial obligation or outstanding balance, regulatory retention laws require the Platform and the NBFC partner to preserve transactional records until the liability is settled.

Correction and Erasure: You may request the rectification of inaccurate data profile elements. Requests for full account erasure are reviewed against active legal and financial preservation mandates.

7. Grievance Redressal Mechanisms

Any inquiries, grievances, or disputes relating to data processing or credit administration may be directed to the respective officers detailed below:

For Platform Interface & Privacy Enquiries (LSP)

For Credit Decisioning, Disbursement, & Sanction Enquiries (NBFC)

8. Amendments

This Privacy Policy may be updated periodically to account for statutory changes, shifts in RBI digital lending frameworks, or platform protocol modifications. Modifications become applicable immediately upon their publication on the Platform interface.

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Have questions about this policy? Contact us at contact@masterfintechltd.com or visit our Contact Us page.

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