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Privacy Policy

Effective: 2 October 2026  ·  Last updated: 2 October 2026

This Privacy Policy (“Policy”) describes how Finipe Ventures Private Limited (“FINIPE Ventures”, “we”, “us”, “our”) collects, uses, discloses, retains and protects personal data in connection with the FINIPE Business Operating System, the developer sandbox, the marketing site at finipe.com, the partner portal, the mobile applications and any related products, APIs, datasets, integrations and documentation (collectively, the “Services”). It applies to every persona class — Distribution Network agents and distributors, SaaS / White-Label tenants, API Developers and Lead Partners — and to anyone visiting our marketing site or engaging with us in a pre-sales capacity.

This Policy is published in compliance with the Digital Personal Data Protection Act, 2023 (“DPDP Act”), the Information Technology Act, 2000 read with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, the Information Technology (Intermediaries Guidelines and Digital Media Ethics Code) Rules, 2021, and applicable directions of the Reserve Bank of India for regulated entities that deploy FINIPE as white-label infrastructure. Where you access the Services from a foreign jurisdiction in which FINIPE Ventures has launched (planned: UAE, Singapore, US, EU), additional local privacy notices may apply and prevail over conflicting provisions of this Policy in respect of that jurisdiction.

By accessing the Services, ticking the “I agree to the privacy policy & terms” checkbox at registration, or otherwise providing personal data to us, you acknowledge that you have read and understood this Policy. Please read it together with our Terms & Conditions.

1. Roles & identity of the Data Fiduciary

Finipe Ventures Private Limited (CIN U82990RJ2026PTC113025), with its registered office at 21, 6th Floor, Bhamashah Techno Hub, Jhalana Dungri, Malviya Nagar, Jaipur, Rajasthan 302017, India, is the Data Fiduciary in respect of personal data we determine the purpose and means of processing for (e.g., marketing-site visitors, prospects, registered users, partners). Where we process personal data solely on behalf of and on the documented instructions of a tenant organisation (e.g., end-customer KYC submitted via a Distribution Network operator’s workflow), we act as a Data Processor for that tenant, and the tenant is the Data Fiduciary.

All privacy questions, grievances, consent withdrawals and Data Principal requests should be addressed to our Grievance Officer / Data Protection Officer (Veerendra Kumar) at connect@finipe.com with subject line beginning “Privacy —”.

2. Personal data we collect

2.1 Information you provide

  • Identity & contact: name, email, mobile, designation, organisation, address.
  • Account credentials: hashed password, multi-factor seed (TOTP), session metadata.
  • Persona-specific identifiers: persona class (Distribution / SaaS / API / Lead Partner), tenant ID, role, downline tree position, employee code, business owner code.
  • Business KYC: CIN, GSTIN, PAN of entity, certificate of incorporation, MOA/AOA, board resolution, signatory ID, beneficial-owner declarations, bank-account proof.
  • Individual KYC (downline / lead / end-customer): name, date of birth, address, Aadhaar number (with masking), PAN, photo, biometric / OTP-based authentication artefacts captured by the relevant Third-Party Provider, video-KYC liveness frames where applicable.
  • Financial data: bank account number, IFSC, UPI handle, wallet balance, transaction history, commission ledger, settlement statements.
  • Loan-DSA lead inputs: borrower’s name, contact, loan type, requested amount, employer, income proxy, credit-bureau consent.
  • Support content: tickets, documents uploaded, screen captures, chat logs, voice recordings (if explicitly enabled).

2.2 Information collected automatically

  • Device & network: IP address, device fingerprint, OS, browser, locale, time zone, referrer URL.
  • Website analytics (our own, first-party) — only if you allow it: on our public web pages, and only after you choose “Allow analytics” — pages viewed, links and buttons clicked (with their position on the page), scroll depth, time on page, referring page, campaign (UTM) tags, browser, device type, screen size, language and time zone, and page-performance timings, linked to a random visitor identifier. Your IP address is stored only as a one-way hash. Until you choose, or if you decline, none of this is collected. Details are in section 9.
  • Location: geo-coordinates only with explicit consent (e.g., field-agent attendance).
  • Security telemetry: authentication events, IP reputation, rate-limit hits, audit-log entries, hash-chained signatures, anomaly-detection scores.

2.3 Information from third parties

  • Verification providers: UIDAI Aadhaar (via licensed AUA / KUA), NSDL PAN, GSTN GSTIN, CKYCR, Digilocker, Karza, IDfy.
  • Account-Aggregator: Setu / Finvu — only on Data Principal’s explicit, FIU-routed consent.
  • Payment & settlement partners: Bill Avenue (BBPS), Razorpay (Payouts & UPI VAN Collections) — transaction confirmations, dispute and chargeback events.
  • Loan-DSA aggregators: Urban Money, Ruloans, Andromeda Sales & Marketing — disbursement status and revenue-share data.
  • Bureau / underwriting: only on the borrower’s explicit consent and only in connection with the Loan DSA Lead Management module.
  • B2B contact enrichment: publicly available business contact data, used strictly for lawful B2B outreach with opt-out on first contact.

2.4 Sensitive personal data

We treat the following as sensitive and apply enhanced safeguards: Aadhaar number (always tokenised and masked at rest), biometric authentication artefacts, financial information, account passwords, sexual orientation (never collected), medical history (never collected), bureau scores (only with explicit consent for the Loan DSA module).

3. Why we process your personal data

  • Provision, operate, secure, monitor and improve the Services.
  • Authenticate users, enforce access controls, prevent fraud, detect intrusion and protect platform integrity.
  • Process commission accruals, distributions, recoveries, settlements and payouts via the ledger and commission engines.
  • Route Loan DSA leads to aggregator partners and reconcile revenue-share.
  • Issue invoices, collect fees, render tax-compliant documentation.
  • Communicate service notices, regulatory advisories, security advisories and product updates.
  • Comply with the DPDP Act, the Information Technology Act, 2000, the Prevention of Money Laundering Act, 2002, the Companies Act, 2013, the Income-Tax Act, 1961, the CGST Act, 2017, RBI master directions, NPCI scheme rules and applicable foreign law where we operate.
  • Conduct research, analytics and aggregated benchmarking — using de-identified or aggregated data wherever feasible.
  • Pursue or defend legal claims and respond to lawful requests by regulators or courts.

4. Lawful basis under the DPDP Act

We process personal data on one or more of the following lawful bases:

  • Consent — for marketing communications, the website analytics and session recording described in section 9, Account-Aggregator data pulls, bureau pulls and any other purpose where consent is required.
  • Performance of contract — to provide the Services to the Tenant and the Authorised User.
  • Compliance with legal obligation — KYC, AML, tax, RBI reporting, audit log retention, regulator response, sanctions screening.
  • Legitimate uses as defined in section 7 of the DPDP Act, where applicable, including (a) provision of subsidies / benefits with prior consent, (b) employment-related processing, (c) breach response, (d) fraud prevention.

Where consent is the basis, an itemised, plain-language consent notice is presented at the point of collection in compliance with section 5 of the DPDP Act. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

5. How we share personal data

We do not sell personal data, and we do not share personal data for cross-context behavioural advertising. We disclose personal data only as set out below:

  • To the tenant organisation on whose behalf the data was collected (Distribution upline, SaaS administrator, API integrator, Lead Partner manager).
  • To Third-Party Providers (sub-processors) that deliver part of the Services — cloud hosting, communication gateways, payment rails, KYC providers, loan aggregators and error monitoring — as listed in section 14.
  • To regulators, courts, law enforcement in response to lawful requests, or to comply with mandatory reporting (Suspicious Transaction Reports, audit responses, breach notifications).
  • To professional advisers (auditors, lawyers, accountants) under confidentiality obligations.
  • To a successor entity in the event of a merger, acquisition, restructuring or asset sale, subject to the successor honouring this Policy.
  • With your explicit consent for any other purpose disclosed at the time of consent.

6. International data transfers

FINIPE is built as a worldwide platform with phased rollout starting in India. Personal data is primarily stored in the AWS Mumbai (ap-south-1) region. Where the Services are extended to UAE, Singapore, US or EU jurisdictions, data may be replicated to a region permissible under the DPDP Act and the destination jurisdiction’s law. Cross-border transfer is performed only where (a) the destination is not blacklisted by the Central Government under section 16 of the DPDP Act, (b) the recipient is bound by appropriate contractual safeguards, and (c) the data principal has been notified of the transfer.

7. Retention

We retain personal data only as long as necessary to fulfil the purposes described in this Policy or as required by applicable law. Indicative retention periods (subject to the Retention Policy Matrix published inside the platform):

  • Transaction ledger & audit log: ten (10) years from the date of transaction (RBI / PMLA / IT Act).
  • KYC documents: minimum five (5) years from cessation of business relationship; longer if required by law-enforcement.
  • Tax invoices & financial records: eight (8) years (Companies Act, GST, Income-Tax Act).
  • Support tickets and chat logs: three (3) years.
  • Website analytics: page-view and click records currently have no automatic deletion date; session recordings (section 9) are deleted automatically after at most thirty (30) days.
  • Fini Proof evidence uploaded to a Developer workspace: kept in an append-only record, as described in section 23.
  • Account credentials & session metadata: until ninety (90) days after account closure.
  • Backups & disaster-recovery snapshots: thirty-five (35) days rolling.

Records subject to statutory retention are preserved on tamper-evident storage (S3 Object Lock or equivalent) even after a Data Principal’s erasure request, with access restricted to authorised compliance personnel.

8. Your rights as a Data Principal

Subject to the DPDP Act and applicable law, you may:

  • Obtain a summary of personal data we hold about you and the identities of recipients;
  • Request correction, completion, updating or erasure of personal data;
  • Withdraw consent previously given (without affecting prior lawful processing);
  • Nominate another individual to exercise these rights in the event of your death or incapacity;
  • Receive readily available means of grievance redressal;
  • Lodge a complaint with the Data Protection Board of India after exhausting our internal grievance process.

To exercise any of these rights, write to our Grievance Officer at connect@finipe.com with subject line beginning “Data Principal Request — ”. We will verify your identity and respond within timelines mandated under the DPDP Act (presently up to thirty (30) days for substantive responses, extendable on intimation for complex matters). Repeated, manifestly unfounded or excessive requests may be refused or charged at cost in accordance with the DPDP Act.

9. Cookies & similar technologies

We use cookies and similar browser storage for two purposes, and we do not use third-party analytics, advertising or cross-context tracking cookies:

  • Strictly necessary: sign-in and session continuity, security, CSRF protection and remembered preferences (such as your region). The Services do not work without them.
  • Our own website analytics — only after you allow it: every public web page of ours that measures visits first asks whether you allow analytics. Until you answer, nothing is measured: no page view, click, scroll, timing, device or campaign information is sent, and no analytics cookie is set. Your answer itself is remembered in your browser’s local storage (strictly necessary, so that we do not ask again on every page).
  • If you choose “Allow analytics”: a random visitor identifier is kept in a first-party cookie (finipe_vid) for three hundred and sixty-five (365) days and a session identifier in your browser’s session storage, and the page activity listed in section 2.2 is sent to our own servers. A small, random sample of visits may also be recorded as a session replay — fields that look like passwords, PINs, OTPs, Aadhaar, PAN, card or bank numbers are masked before anything leaves your browser.
  • If you choose “Reject”: nothing is measured and no session replay is recorded, and any analytics identifiers stored earlier in your browser are deleted. Contact forms still work; they are sent without any analytics identifier.

To change your answer, delete this site’s cookies and site storage from your browser settings; you will be asked again on your next visit. Blocking strictly-necessary cookies will impair the Services.

10. Security measures

We implement reasonable technical and organisational security measures aligned with ISO 27001 control families and the IT Rules 2011. These include:

  • TLS 1.2+ encryption in transit; AES-256 encryption at rest for sensitive fields and at-rest blob stores.
  • Tokenisation and masking of Aadhaar and similar high-sensitivity identifiers.
  • Role-based access control with scope-ceiling and downline-tree enforcement; multi-factor authentication for privileged roles.
  • Tamper-evident hash-chained audit log persisted to S3 Object Lock; hourly anchor verification.
  • IDOR-impossible-by-construction API layer; rate limiting; replay-protected idempotency.
  • Segregated environments (sandbox / staging / production); least-privilege CI/CD with signed deploys.
  • Vendor due diligence with executed Data Processing Agreements; periodic re-attestation.
  • Independent penetration testing prior to MVP general-availability and at least annually thereafter.
  • Continuous integrity verification at application boot.

No system is completely secure. If you believe an account has been compromised, write immediately to connect@finipe.com with subject line beginning “Security —”.

11. Personal data breach

In the event of a personal data breach as defined under the DPDP Act and the IT Rules, we will (a) notify the Data Protection Board of India and affected Data Principals without undue delay in the form and content prescribed under applicable rules, (b) notify CERT-In within the timelines required under the CERT-In Directions of 28 April 2022, and (c) cooperate with affected Tenants and regulated counterparties to mitigate harm.

12. Children

FINIPE is a B2B platform and is not directed at, nor intended for use by, children below the age of eighteen (18). We do not knowingly collect personal data of children. If we learn that we have collected such data, we will delete it without undue delay. The DPDP Act’s additional protections applicable to children and persons with disabilities are observed where relevant (e.g., a Lead Partner’s borrower file involving a minor co-applicant).

13. Persona-specific notices

13.1 Distribution Network

End-customer KYC, transaction logs and dispute records collected by Distribution Network operators are processed by FINIPE Ventures as a Data Processor on the Tenant’s instructions and shared with the relevant rail (Bill Avenue / Razorpay) for transaction execution. Wallet tier limits apply and structuring is monitored.

13.2 SaaS / White-label

Tenant data is isolated by tenant ID and, for White-Label Tenants, by custom subdomain. Cross-tenant access is not possible by construction. Aggregated, de-identified usage metrics may be used to improve the Services.

13.3 API Developer

API key metadata, request logs, idempotency keys and webhook delivery telemetry are retained for security and billing reconciliation. Sandbox transactions use synthetic data and are not retained beyond ninety (90) days unless escalated as a support ticket.

13.4 Lead Partner (Loan DSA)

Borrower data submitted to the Loan DSA Lead Management module is shared with one or more aggregator partners (Urban Money, Ruloans, Andromeda) for sourcing offers. Bureau pulls are performed only on the borrower’s explicit consent. Lead Partners must furnish the borrower with a copy of this Policy at the point of collection.

14. Sub-processors

We use the providers below to deliver the Services; each receives only the personal data its function needs. Which provider serves a given tenant or channel is set in the platform’s provider configuration, visible to Tenant administrators under System > Provider Credentials, and this list is updated when a provider is added or removed.

  • Cloud hosting, storage and AI model processing: Amazon Web Services, Mumbai (ap-south-1) region primary, including Amazon Bedrock for the AI assistant.
  • SMS one-time passwords and notices: PWASMS.
  • E-mail delivery: Microsoft 365.
  • Mobile push notifications: Google Firebase Cloud Messaging.
  • WhatsApp messaging: Meta WhatsApp Business Platform.
  • Payment and BBPS rails: Bill Avenue / Euronet, Razorpay, and Cashfree where a payment service using it is enabled.
  • KYC and document verification: Karza, IDfy, Setu / Finvu.
  • Loan DSA aggregators: Urban Money, Ruloans, Andromeda.
  • Application error monitoring: Sentry, where enabled.

15. Direct marketing & preferences

We send service notices, regulatory advisories and security advisories regardless of marketing preference because they are essential to the Services. Marketing emails are sent only to recipients who have opted in or who fall within a permissible legitimate-use scenario; every marketing email carries an unsubscribe link and your decision is honoured immediately.

16. Automated decision-making

Certain Services use rule-based or model-driven scoring (e.g., lead-scoring v2, anomaly detection, KYC tier-up recommendations). These are decision-support tools — final decisions are taken by humans within the Tenant organisation or the relevant rail. We do not use solely-automated decisions producing significant legal effects on a Data Principal without affording them an opportunity to be heard.

17. Changes to this Policy

We may update this Policy from time to time. Material changes will be notified at least fifteen (15) days in advance via email to your registered address and via in-app banner. The “Last updated” date at the top of this page reflects the most recent revision. The latest version is always available at finipe.com/privacy-policy.

18. Contact & grievance redressal

For any privacy question, grievance, withdrawal of consent, Data Principal request or report of a suspected breach, write to our Grievance Officer / Data Protection Officer (Veerendra Kumar) at connect@finipe.com. Postal correspondence may be addressed to Finipe Ventures Private Limited, 21, 6th Floor, Bhamashah Techno Hub, Jhalana Dungri, Malviya Nagar, Jaipur, Rajasthan 302017, India. Acknowledgement is sent within forty-eight (48) hours and resolution targeted within the timelines mandated by the DPDP Act. Unresolved grievances may be escalated to the Data Protection Board of India.

19. Marketplace and Supplier Data

When you list your business on FINIPE as a supplier, we collect and process:

  • Business identity information: name, address, contact, GSTIN, CIN, and applicable professional licences such as RERA registration, IRDAI agency code, DCGI licence, FSSAI registration, and Bar Council enrolment.
  • Listing performance data: view counts, lead receipt counts, conversion metrics, and response rate.
  • Transaction and fulfillment records: escrow transactions, dispute history, and settlement receipts.
  • Trust Score components: derived from audit events, KYC tier, SLA adherence, and verified review aggregates.

Supplier data is processed under the purpose "marketplace demand routing" and retained for the duration of an active listing plus three (3) years after deactivation. You may request deactivation and erasure as described in the Your Rights section above (section 8).

20. AI Memory and Cross-Vertical Profiling

FINIPE's AI assistant maintains a memory of your interactions across our service categories (for example, if you enquire about property, we may infer that a home loan recommendation is relevant). This cross-vertical profiling is stored in your account under ai_preferences.memory_enabled. You may disable this at any time from Settings & Privacy inside the FINIPE AI interface.

Life-stage tags derived from your activity (for example, considering_property_purchase or has_loan_inquiry) are stored in your account profile and are used solely to personalise AI recommendations. They are never sold to third parties. You may request their deletion via the erasure request process described in section 8 of this Policy.

21. Mobile applications — device permissions and Google Play Data safety

This section describes exactly what the current FINIPE Android application (package com.finipe.finipe_app, distributed through Google Play) asks your device for, and is the description our Google Play Data safety declaration refers to. Every permission below is optional, is requested only when you first use the feature that needs it, and can be withdrawn at any time from Android Settings → Apps → FINIPE → Permissions.

  • Microphone (RECORD_AUDIO): to take voice input for the FINIPE AI assistant and to carry audio on calls you place in the app. The microphone is active only while you hold or turn on the microphone control or are on a call. Where speech is converted to text on our servers, the audio is used for that request only; the resulting text is handled under section 20.
  • Audio routing and Bluetooth (MODIFY_AUDIO_SETTINGS, BLUETOOTH_CONNECT): to route call audio to your speaker, earpiece or a paired Bluetooth headset during an in-app call. We do not scan for Bluetooth devices and collect nothing about them.
  • Camera (CAMERA): to scan a document you choose to capture. A captured page leaves your device only if you then send or save it to your account.
  • Storage (WRITE_EXTERNAL_STORAGE, requested only on Android versions that still require it): to save a scanned page or an exported document to your device's gallery when you ask the app to.
  • Phone number (READ_PHONE_STATE, READ_PHONE_NUMBERS): to read the phone number of the SIM in your device so sign-in can verify it without an SMS. It is used for that verification only. We do not read your call log or place calls.
  • Biometrics (USE_BIOMETRIC, USE_FINGERPRINT): to unlock the application with the fingerprint or face already enrolled on your device. The biometric never leaves the device; Android tells the app only whether the check succeeded.
  • Notifications (POST_NOTIFICATIONS) and full-screen intent (USE_FULL_SCREEN_INTENT): to show alerts you have turned on, and to ring an incoming in-app call on a locked screen.

What the current app does not request. It does not request access to your contacts or to your device's location. If a future version needs either, this section will be updated before that version is released, and Android will ask for your permission at the time of first use.

All data in transit between the application and our servers is encrypted with TLS 1.2 or above, as described in section 10. We do not sell personal data, and we do not share it with third parties for advertising or independent marketing purposes. Data shared with the sub-processors listed in section 14 is shared only to deliver the Services.

22. Deleting your account and your data

You can ask us to delete your FINIPE account and the personal data associated with it at any time, free of charge, by either route:

  • In the Android app — Profile → Settings → Delete account & data. The app explains what will happen and then opens the request page below.
  • Without signing in — submit a request at finipe.com/dpdpa-dsr (also reachable at finipe.com/data-deletion) and choose Erasure. We verify your identity with a one-time password sent to your registered mobile number before we act, so that nobody else can erase your data.

What is deleted. Your profile, login credentials, contact details, device and session records, assistant memory and life-stage tags (section 20), uploaded documents, saved preferences and the contents of your chats are deleted or irreversibly anonymised.

What is retained, and why. We are required by law to keep certain records even after an account is closed, and we keep only those: transaction, invoice and books-of-account records for the period prescribed under the Companies Act, 2013 and applicable tax law; KYC records for the period prescribed by the Prevention of Money-Laundering Act and Reserve Bank of India directions; records under legal hold or needed to establish, exercise or defend a legal claim; and minimal audit entries proving that the deletion itself took place. Retained records are locked to their legal purpose and are not used to contact you or to build any profile. Retention periods are in section 7. Fini Proof evidence uploaded to a Developer workspace is handled differently, as explained in section 23.

Timeline. A verified request is completed within thirty (30) days, save for the retained categories above. If your account is a business account with other members, or carries an unsettled balance or an open order, we will tell you what must be resolved first, and why, before deletion completes.

23. Fini Proof — code-verification data

Fini Proof is a code-verification tool that runs on your own machines and CI runners, with an optional hosted Developer workspace. Its licence and service terms are in section 25 of our Terms & Conditions.

23.1 What stays on your machine

The command-line tool reads your repository locally and does not send your source code to us. Its evidence files, its trial record and its usage meter are written to your machine; the usage meter keeps commit-author e-mail addresses only as one-way (SHA-256) hashes. A licence key is checked on your machine without any network call. Nothing reaches us unless you, or your CI, run the tool with its upload option and a workspace API key.

23.2 What we receive when you use the Developer workspace

  • Workspace records: your FINIPE account, the workspaces, businesses and repositories you belong to and your role in them, and who added or removed members, repositories, API keys and licences, with timestamps.
  • Repository records: repository name (for example owner/name), code-hosting provider, repository URL and default branch.
  • Uploaded runs: repository name, branch and commit identifier; the file paths and SHA-256 hashes of the files checked; each finding’s rule, file path, line and message (a detected secret appears only in shortened, redacted form); verdicts and proof states; tool and engine versions; a hash of the CI runner’s host name; the “maker” of the change (the commit author’s e-mail address, or an agent name, model and session if you configure them); the commit author’s e-mail address and a SHA-256 hash of it; the account and API key that uploaded the run; and any verifier signature.
  • API keys: each key is shown once when created. We store only a SHA-256 hash of it, its last four characters, its name and scope, who created it, and when it was created, last used and revoked.
  • Licence keys issued in the workspace: the organisation name, seats, expiry and issuer, and a copy of the key so that your administrators can download it again.

23.3 Why we use it

  • To show runs, findings and proof states to the members of your workspace, according to their role. A member without workspace-management rights sees only the runs of repositories belonging to businesses they own, the runs they uploaded, and the runs whose commit-author e-mail matches the e-mail on their account.
  • To count active contributors for billing, using the hash of the commit-author e-mail.
  • To authenticate uploads, refuse edited or forged evidence, prevent abuse and secure the service.
  • To provide support and to comply with law.

We do not sell this data, use it for advertising, or use your code or evidence to train or fine-tune any artificial-intelligence model. Where your organisation uploads evidence that contains its contributors’ details, your organisation decides what is uploaded and should tell its contributors; we process that data to provide the service to your organisation.

23.4 Retention, and what deletion can and cannot do

Uploaded runs, their findings and the related file snapshots are stored in an append-only record: the database refuses any change or deletion of an individual run, by anyone — including us — so that the record can be trusted as evidence. Deleting a repository in the workspace hides it but keeps its runs. Revoking an API key or a licence key keeps the record that the key existed. There is currently no automatic deletion date for these records.

This means that an erasure request under section 8 cannot remove a commit-author e-mail address from runs that have already been uploaded. If you make one, we will tell you which records hold your data and why, and we will continue to use those records only for the purposes in clause 23.3. If you do not want a personal e-mail address to appear in uploaded evidence, commit with an address that is not personal (for example your code host’s “no-reply” address), or do not use the upload option. Your other account data is deleted as described in section 22.