Policies

1. Introduction

This website www.stashfin.com, its mobile phone application(s) and other related internet-based applications including StashFin app (collectively referred to as “StashFin Platform”) owned and operated by Akara Capital Advisors Private Limited , a company incorporated under the laws of the Republic of India having its Corporate Office at 1st Floor, CRC2 Building, Khasra No. 337, Sultanpur, New Delhi, 110030, India.
General terms and conditions for the use of StashFin Platform and other terms/disclaimers of StashFin Platform are incorporated hereby way of this reference. They shall be read as an integral part hereof.

2. General

StashFin Platform asks for and uses your personal information and is committed to keeping this information secure and protected. This Privacy Policy explains why we require personal information and how we collect, use, disclose and secure your personal information. This Privacy Policy applies to the personal information we collect from you and third parties, both online and offline. However, it does not apply to any personal information collected by third parties from you.
By accessing or using the StashFin Platform or any of its services, you signify that you have read, understood and confirm to be bound by this Privacy Policy and its modifications. We reserve the right to update or modify this Privacy Policy at any time without prior notice. Therefore, we encourage you to review this Policy each time you access our Services on StashFin Platform. We may also notify you of material changes to the Privacy Policy by e-mail or by a notice on our home page.
The following terms and definitions have been set out in this privacy policy:
- “StashFin”, “we”, “us”, and “our” means Akara Capital Advisors Private Limited
- “you” and “your” means a user of the StashFin Platform and the products and services provided via the StashFin Platform.
- “Services” includes lending and any other related services facilitated by us via StashFin Platform.

3. Collection of User Information

To create an account on StashFin Platform, you must provide us with the basic details and information required as part of our Customer Identification process. You confirm to our General Terms and Conditions for the use of StashFin Platform, this Privacy Policy and other terms, which govern how we treat your information.
During the use of our Services, StashFin Platform, we may collect information about you from you and third parties. While some data has to be mandatorily provided, others are optional. Certain portions of the data will remain private, and some will be shared with associated third parties. All information you provide to us is voluntary. This information is including but not limited to, the following:
1. Information about you when you register or when you use our StashFin Platform
2. Personal and financial information like your name, e-mail address, contact number, gender, date of birth, contact information, address, employment information, payslips, academic qualification, PAN no., Driving License no., Aadhaar no., bank statements, etc.
3. Credit-related information that is collected from other sources like credit bureaus.
4. Information about your transaction history like spend data, through our app etc.
5. We may also collect other personal information such as SMS, contacts, location data, mobile device data etc.
6. Your unique identifiers, such as username and password preferences information and transaction history.
7. Information collected through your Facebook, Twitter, LinkedIn or other social media accounts which have been linked to the account on the StashFin Platform.
8. Information that you provide when you write directly to us (including by e-mail) or provide us over the telephone.
9. Any other information that StashFin is required to collect per a specific mandate from any bank or as a requirement under applicable law.
10. Electronic bank statements through a 3rd party provider.
11. Aggregate information and electronic data – like the pages viewed, how you navigate the website, and interact with web pages, etc.
12. Permissions given by you through android or iPhone operating system or other operating systems based on your informed consent inter alia for access to maps, device information like IMEI, android id/iPhone id/operating system based ID, network sockets, information about networks, information about Wi-Fi networks, camera, read-only access to phone state, including the current cellular network information, the status of any ongoing calls, user SMS data, user contacts, data in external storage like the image for selfie storage, data from external storage, allow the application to use fingerprint biometric services, details of installed applications on your device/s and other permission as may be specifically sought.
We may collect and monitor each installed applications metadata information that includes application and package name, installed and updated time, version name and version code for all applications installed on your device. These details about installed applications on your device is collected in order to decide your creditworthiness, provide customized offers and facilitate faster approval. Such details may be collected after the registration is complete and such data is not shared with any individual or third-party application other than for the services sought by you.
The information we collect about you will depend on the products and services we offer on an ongoing basis. If you do not allow us to collect all the information we request, we may not be able to deliver all of these services effectively.
You understand that, by creating an account or by registering through third party sites, we and others will be able to identify you by your StashFin profile. However, we will not be liable under any circumstance for the generation of your profile or the information you provide therein. StashFin will also not be responsible and liable for any information collected in the form of SMS, contact, media or any other sources that the users might upload, the data collection process may extract, the use and misuse thereof. We will ask for your bank account details only for the Service.
All the information that you shall provide us is voluntary, including sensitive personal information. You understand that StashFin may use certain information of yours, which has been designated as ‘sensitive personal data or information’ under the applicable regulations to provide you the Services directly or through third parties.
You can contact us or mute the notification yourself in our application for withdrawing your consent to provide the personal information.

4. Use of your information

We may use the information you provide in the following ways:
1. To establish and confirm identity for assessing applications.
2. To capture the user information given in the application forms and any information uploaded on StashFin Platform by you, such as KYC documentation, bank slips and credit information.
3. Share the information with partner Banks, NBFCs, multiple financial institutions, and other lenders to customize offers and provide services.
4. To manage our customer relationships, get in touch with customers to send communications, notifications, information, or process queries and applications made by customers on StashFin Platform as well as to you about other products or services we think you might find of some use.
5. Design our products, offer our products and services, manage our risks, including the risk of fraud.
6. Analyze how the StashFin Platform is used, diagnose service or technical problems and maintain security.
7. Monitor, improve and administer StashFin Platform.
8. Comply with country laws and regulations.
9. Use this information in other ways permitted by law.
We use personal information to provide you with services & products you explicitly requested for, to resolve disputes, troubleshoot concerns, help promote safe services, collect money, measure consumer interest in our services, inform you about offers, products, services, updates, customize your experience, detect & protect us against error, fraud and other criminal activity, enforce our terms and conditions, etc.
We also use your contact information to send you offers based on your previous orders and interests.
We may occasionally ask you to complete optional online surveys. These surveys may ask you for contact information and demographic information (like zip code, age, gender, etc.).
We use data submitted by you to customize your experience at StashFin Platform, providing you with content that we think you might be interested in and display content according to your preferences.

5. Third-party sharing of your information

We will take the utmost care to ensure that your personal information is not shared with the public and that your transactions on the StashFin Platform are confidential. If we use any third parties for any of these transactions, we will also ensure that confidentiality is maintained with these authorized third parties. We only share your personal information with unaffiliated third parties as permitted or required by law. When we share your personal information with vendors and service providers who perform functions on our behalf, they informed to keep your information confidential and secure and use it only as is reasonably necessary to carry out their work or comply with applicable law.
We may share your personal information with affiliates and joint marketing campaigns with other financial companies. Also, personal information may be disclosed or transferred to our affiliates and as part of, or during negotiations of, a merger, consolidation, sale of company assets or equity, financing, acquisition, strategic alliance or in any other situation where personal information may be transferred as one of the business assets of StashFin.

6. Protecting your information

We maintain administrative, technical and physical safeguards designed to protect the security, confidentiality and integrity of your personal information. We store all the customer data on AWS cloud servers to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls, SSL data encryption and access authorization controls. Also, your personal information resides on servers or in areas of facilities that only selected StashFin personnel and contractors have access to.
However, you understand and accept that there’s no guarantee that data transmission over the Internet will be completely secure and that any information that you transmit to us is at your own risk. We assume no liability for any disclosure of data due to errors in transmission, unauthorized third party access to StashFin Platform and databases or other acts of third parties, or acts or omissions beyond our reasonable control and you shall not be entitled to hold StashFin responsible for any breach of security.

7. Your choices regarding your personal information

Personal information not collected on the StashFin Platform or in connection with the Service is not generally subject to this Privacy Policy. The StashFin Platform may contain links to other websites that may collect personal information. For example, StashFin may have relationships with various service providers whose services you might find useful and available to you from the StashFin Platform, from websites linked to the StashFin Platform, or in connection with the Service. Those providers may require you to provide personal information to use their services. Unless expressly provided to the contrary, the privacy policy applicable to that website, and not this Privacy Policy, will govern the collection, use, disclosure and security of your personal information.
You can access all of your personal and personally identifiable information that we collect online and maintain by logging in to your account and going to “My Profile”. This section of the site is password-protected to safeguard your information better. To protect the confidentiality of such personal data, you should not divulge your password to anyone. You are responsible for all uses of the StashFin Platform by any person using your customer ID and password. As a registered user, you can update, physical address, phone numbers, education and employment information at any time on the website. If you need to change any other information in your profile, contact us through the chat feature on the StashFin Platform.
You can contact us or mute the notification yourself in our application for withdrawing your consent to provide the personal information.

8. Tracking, use of cookies, web beacons and similar tracking devices

Cookies are small data files that a website stores on your computer. StashFin Platform uses cookies for security and to personalize your web browsing experience.
We may use cookies for some situations, such as,
1. To allocate an identification number to your Internet browser (you cannot be identified from this number)
2. To make StashFin Platform more user friendly
3. To determine if you have previously visited the StashFin Platform
4. To track and report on StashFin Platform and online campaign performance
5. To identify other pages or third parties’ websites you have accessed, and
6. For fraud detection and security purposes
7. You can configure your browser so that it does not receive cookies. However, this means you will be unable to use secure services that require cookies to participate

9. Information from advertisements on other websites

We place and track advertisements on third-party websites. Like many advertisers, we advertise our products and services. We contract with third parties to place advertisements on websites not affiliated with us where we think the advertisements are likely to be most relevant. These advertisements may contain cookies or other mechanisms that allow tracking of your response to our ads. Our contracted third parties and we track and report performance of our advertising and marketing campaigns by using cookies, web beacons, and other similar technology, which may be used to collect and store information about user visits, page visits and duration, and/or the specific ad or link that the user clicked on to visit the site.

10. Communication

When you contact StashFin or StashFin contacts you directly or by service providers of StashFin through phone, e-mail or electronic means, at the discretion of StashFin such communications may be stored or recorded by the StashFin or its service providers for the purpose of improvements in customer engagement and to offer more services.
Use of StashFin Platform in any manner by a user shall be deemed as an acceptance to the above by the concerned user.

11. Contacting StashFin

In case you need any details or clarifications or redressal of grievances or have any feedback regarding our Privacy Policy or believe that StashFin has not complied with this Privacy Policy concerning your personal information, please contact us at www.stashfin.com/contact-us. If you are reporting noncompliance with this Privacy Policy, in your e-mail or letter, please describe in as much detail as possible (but without disclosing any sensitive information about you or third parties) how you believe that the Privacy Policy has not been complied with.

Contact Us
Name:	Akara Capital Advisors Private Limited
Address:	CRC-2, 1st Floor, Khasra No. 337, Mehrauli-Gurgaon Rd, Sultanpur, New Delhi, Delhi 110030
Email Id:	[email protected]
Contact No:	+91-7065254281
Contact Person:	Sanjeev Walia
Nodal Officer:	Sanjeev Walia

Fair Practice Code (“FPC” or “Code”)

The Reserve Bank of India (RBI) has issued guidelines on Fair Practices Code for Non-Banking Finance Companies (NBFCs) thereby setting standards for fair business and corporate practices while dealing with their customers vide RBI Master Directions DNBR.PD.007/03.10.119/2016-17 dated September 01, 2016, as amended and updated from time to time.

Akara Capital Advisors Private Limited (“Company”) has adopted all the best practices prescribed by Reserve Bank of India and shall make appropriate modifications, if any necessary, to this Code to conform to the standards so prescribed. The Company will also communicate its Fair Practice Code (“FPC” or “Code”) to its customers by uploading the FPC on its website/mobile application.

The Company is having customer interface and shall therefore, adopt the following guidelines:

1. Applications for loans and their processing:

All communications to the borrower shall be in the vernacular language or a language as understood by the borrower.
Loan application forms shall include necessary information which affects the interest of the borrower, so that a meaningful comparison with the terms and conditions offered by other NBFCs can be made and informed decision can be taken by the borrower.
The loan application form shall indicate the documents required to be submitted with the application form.
The Company shall devise a system of giving acknowledgement for receipt of all loan applications. Preferably, the time frame within which loan applications will be disposed of shall also be indicated in the acknowledgement.

2. Loan appraisal and terms/conditions:

The Company shall convey in writing to the borrower in the vernacular language as understood by the borrower by means of sanction letter or otherwise, the amount of loan sanctioned along with the terms and conditions including annualised rate of interest and method of application thereof and keep the acceptance of these terms and conditions by the borrower on its record. As complaints received against NBFCs generally pertain to charging of high interest / penal interest, the Company shall mention the penal interest charged for late repayment in bold in the loan agreement.
The Comapany shall furnish a copy of the loan agreement or enclosures quoted in the loan agreement. The Company shall furnish a copy of the loan agreement as understood by the borrower along with a copy each of all enclosures quoted in the loan agreement to all the borrowers at the time of sanction / disbursement of loans.

3. Disbursement of loans including changes in terms and conditions:

The Company shall give notice to the borrower in the vernacular language or a language as understood by the borrower of any change in the terms and conditions including disbursement schedule, interest rates, service charges, prepayment charges etc. The Company shall also ensure that changes in interest rates and charges are effected only prospectively. A suitable condition in this regard must be incorporated in the loan agreement.
Decision to recall / accelerate payment or performance under the agreement shall be in consonance with the loan agreement.
The Company shall release all securities on repayment of all dues or on realisation of the outstanding amount of loan subject to any legitimate right or lien for any other claim they may have against borrower. If such right of set off is to be exercised, the borrower shall be given notice about the same with full particulars about the remaining claims and the conditions under which the Company is entitled to retain the securities till the relevant claim is settled/ paid.

4. General

The Company shall refrain from interference in the affairs of the borrower except for the purposes provided in the terms and conditions of the loan agreement (unless information, not earlier disclosed by the borrower, has been noticed).
In case of receipt of request from the borrower for transfer of borrowal account, the consent or otherwise i.e. objection of the Company, if any, shall be conveyed within 21 days from the date of receipt of request. Such transfer shall be as per transparent contractual terms in consonance with law.
In the matter of recovery of loans, the Company shall not resort to undue harassment viz; persistently bothering the borrowers at odd hours, use muscle power for recovery of loans etc. In case the complaints from customers includes rude behavior from the staff of the companies, the Company shall ensure that the staff are adequately trained to deal with the customers in an appropriate manner.
As a measure of customer protection and also in order to bring in uniformity with regard to prepayment of various loans by borrowers of banks and NBFCs, the Company shall not charge foreclosure charges/ pre-payment penalties on any floating rate term loan sanctioned for purposes other than business to individual borrowers, with or without co-obligant(s).

5. Responsibility of Board of Directors:

The Board of Directors of the Company shall also lay down the appropriate grievance redressal mechanism within the organization. Such a mechanism shall ensure that all disputes arising out of the decisions of lending institutions’ functionaries are heard and disposed of at least at the next higher level. The Board of Directors shall also provide for periodical review of the compliance of the Fair Practices Code and the functioning of the grievances redressal mechanism at various levels of management. A consolidated report of such reviews shall be submitted to the Board at regular intervals, as may be prescribed by it.

6. Grievance Redressal Officer:

The Company shall display the following information prominently, for the benefit of their customers, at their branches / places where business is transacted:

The name and contact details (Telephone / Mobile nos. as also email address) of the Grievance Redressal Officer who can be approached by the public for resolution of complaints against the Company.
If the complaint / dispute is not redressed within a period of one month, the customer may appeal to the Officer-in-Charge of the Regional Office of Department of Non-Banking Supervision of the Bank (with complete contact details), under whose jurisdiction the registered office of the Company falls

7. Nodal Officer/ Principal Nodal Officer:

The Company shall appoint Nodal Officer/ Principal Nodal Officer, if required in accordance with law.

8. Regulation of excessive interest charged by the Company:

The Board of the Company shall adopt an interest rate model taking into account relevant factors such as cost of funds, margin and risk premium and determine the rate of interest to be charged for loans and advances. The rate of interest and the approach for gradations of risk and rationale for charging different rate of interest to different categories of borrowers shall be disclosed to the borrower or customer in the application form and communicated explicitly in the sanction letter.
The rates of interest and the approach for gradation of risks shall also be made available on the web-site of the companies or published in the relevant newspapers. The information published in the website or otherwise published shall be updated whenever there is a change in the rates of interest.
The rate of interest must be annualised rate so that the borrower is aware of the exact rates that would be charged to the account.

9. Complaints about excessive interest charged by the Company:

Boards of the Company shall lay out appropriate internal principles and procedures in determining interest rates and processing and other charges. In this regard the guidelines indicated in the Fair Practices Code about transparency in respect of terms and conditions of the loans are to be kept in view.

10. The Company may, subject to relevant terms and conditions offer a Free Credit Period to its customers, wherein the customer will be offered a credit line to make purchases and repay them later:

For no fee or interest charged to them, if the payment is made 5 days prior to the first payment date.
Post the first payment date the the customer shall be required to made payment with applicable interest (based on the tenure customer has chosen at the time of applying).

11. Pursuant to Outsourcing policy issued by Reserve Bank of India, the Company has outsourced certain activities (including but not limited to lead generation, customer support, servicing, collections, business correspondent activities, technology services etc) to EQX Analytics Private Limited, which is an affiliated entity within the same corporate group of the Company.