Version: Feb 22-2022

This Policy has been updated on 22 February, 2022.

1. INTRODUCTION:

We welcome you to Shadhin Fintech Solutions Limited (‘Shadhin’). We value the users of our Website/Application and protection of their privacy and trust are very important to us. We understand that you may be concerned about the collection, use and disclosure of your personal identifiable information (“Personal Information”) shared by you with us. This Privacy Policy describes the information collected from you, mode of collection of this information and manner of handling the same after we collect it from you. By using the Website/Application, you are accepting the practices described in this Privacy Policy. Further, you also give us the consent to use Your Personal Information by Shadhin in accordance with the terms set out in this Privacy Policy. Shadhin urges you to review the information provided in this Privacy Policy.

2. DEFINITIONS: 

“Affiliates” mean parties with whom Shadhin have an existing business relationship through a legal instrument. 

“Application” refers to the Company’s mobile application and Web Application. Hereinafter also refereed as App. 

“Applicable Law” means “Laws of Bangladesh”

“Data” means information which is intentionally processed by means of equipment operating automatically or otherwise. 

“Data Subject” means an individual who is the subject of the personal data. 

“Non-Personal Information” includes information that your phone sends to us each time our application is accessed which includes your phone’s Internet Protocol address, phone model, our service-related pages you visit, time and date of your visit, time spent on these pages and preferences that are generated based on the data you submit and number of clicks. 

“Personal Information” means any information related to an identifiable individual/business that is provided to us at the time of registration or while obtaining our Services. Personal Information can be categorized as follows:

  • Identity Data (for example, user’s name, contact number, billing and shipping address, e-mail address, etc); and
  • Economics and transactions (for example, card details, payment information, banking information, credit information, Tax documents, financial transaction history, etc). 

“Services” refer the products or services offered by Shadhin

“User” or “you” or ““your” shall mean any Person who accesses, downloads, uses and/or views this website and/or the services. 

“Website” refers to the Company’s website https://shadhinbd.com/.

 “We”, “Us”, “Our” and “Shadhin” refer to the Company.

The terms not defined in this Privacy Policy shall have the meanings ascribed to them in the agreement entered into between Shadhin and you. 

3. INFORMATION WE COLLECT 

For the purpose of providing our Services or communicating with you effectively, we will require you to provide among others the following types of information: 

  1. Personal Information: We collect information/documents from you when you register on the Website/App, when you create a profile on the Website/App, when you update your profile on the Website/App, when you use the features on the Website/App, when you participate in surveys conducted by Shadhin on the Website/App and when you carry out transactions on the Application. The term Personal Information shall include your name, address, gender, date of birth, marital status, e-mail id and mobile phone number, your NID number, your images and photos, if any etc. In terms of financial information, we collect some Professional information like- Employment type, Monthly income, Company Details (Name, Address, Contact Number, Website, Email), Outstanding Loan Details etc. and we also may collect Bank Statement, Salary Certificate, Utility Bill (Water, Electricity Gas) for our e-KYC. Again, We require your consent for collecting and monitoring the information about the location of your device determine serviceability of your application.  
  2. Non-Personal Information:  We collect Non-Personal Information to track the use of the Application and Shadhin Services and for other internal purposes, such as providing, maintaining, evaluating, and improving Services and the Application.
  3. Communications with Shadhin: If you communicate with us regarding the Shadhin Application or Website or its connected services, we will collect any information that you provide to us in any such communication.
  4. Analytic and Reporting Technologies: Like the operators of most websites and mobile application, we use analytic and reporting technologies to record Non-Personal Information such as Internet domain and host names, Internet protocol (IP) addresses, browser software, operating system types, clickstream patterns, and the dates and times that the Application or Website and Services are accessed.
  5. Information collected from third parties: We may receive information about you from third parties, including information we request from credit reporting agencies from other partners. We will collect information, which may include your credit history and credit scores, from credit bureaus and other partners to determine your creditworthiness if you are a borrower, assess risks related to your potential funding, and to help investors determine whether to commit to your funding. If you consent to have Shadhin request your financial data directly from your financial institution, we may work with a third party to access and collect such data on our behalf. 

4. CONSENT

By signing up for any of the Services or dealing with any individual investor or investee using Shadhin’s Services, you are agreeing to the terms of this Privacy Policy and, as applicable, the Shadhin Terms of Service. This Policy is a legally binding agreement between you including your client, employee, authorized representatives, employer or another entity if you are acting on their behalf as the user of the Services (referred to as “you”, “your” or “user”) and the Company. Upon acceptance of these terms and conditions, you hereby grant an unequivocal and absolute consent to share your personal information (but not your Sensitive Personal Data / Information) with third parties. Shadhin is not required to seek your consent once again in respect of sharing your personal information with third parties. If we add any new features, functionalities or tools to our Services, they will also be subject to this Policy.

5. USE OF INFORMATION & DISCLOSURE

  1. Depending on how you interact on our Platform, we will process your Personal and Non-Personal Information to manage your registration as user of our Application (for example, identifying you as a user, granting you access to various Services and functionalities, etc);
  2. Your Data is collected and retained by us to customize your experience in using this Website/App, such as for the following purposes: to troubleshoot problems, to respond to your enquiries, requests and emails to provide clarity on the Services offered on this Website/App and fulfill requests for information regarding the Services offered by Shadhin in this Website/App to send you information related to the Services to send you marketing communications, surveys, advertisements, products and offers that may align with your interests to enable you to use this Website/App. 
  3. We will also continue to store anonymous or anonymized information, such as website visits, without identifiers, in order to improve our Services. 
  4. We may disclose Personal Information to our affiliates in your local jurisdiction or other locations as necessary or appropriate to provide the product or service you requested, to contact you in connection with product or service offerings, or for other legitimate business purposes. The names and addresses of our affiliates are published along with our design, products and services on our Website/App.
  5. We would share your personal information with marketing agencies and other businesses if we in our sole discretion understand that your information may be used to market the Application or a product or service. We may also make public your personal information in relation to any testimonials and feedback that you may provide us with and you hereby grant us the right to make such testimonials and feedback public on any public platform that we may choose. 
  6. We may use third party service providers to serve ads on our behalf across the Internet and sometimes on the Shadhin Application or website. They may collect anonymous information about your visits to our Shadhin Application or website, and your interaction with our products and services. They may also use information about your visits to this and other websites to target advertisements for goods and services.
  7. We will use your data for internal purposes such as the following: to conduct internal reviews and data analysis for this Website/App, improve the Services on this Website/App and tailor the Content and advertising to efficiently meet the needs of Users to safeguard the integrity of this Website to conduct internal reviews and data analysis of this website. 
  8. We may disclose your Personal Information to any successor-in-interest of ours, such as a company that acquires us. In the event Shadhin goes through a business transition, such as a merger or acquisition by or with another company, or sale of all or a portion of our assets, your Personal Information will likely be among the assets transferred. You will be notified via email or by a notice on our Website/App of any such change in ownership or control of your Personal Information. 
  9. We may disclose your Personal Information and/or Sensitive Personal Data / Information to prevent an emergency, to respond to legal requirements, to protect or enforce our rights and policies, to protect or enforce the rights of a third party, or as required or permitted by law (including, without limitation, to comply with a summon or court order).
  10. We will further share your Personal Information where we have consent from you to share the same.

6. PROTECTION OF INFORMATION: 

  1. We will keep your information untampered and as it is, as provided to us by you.  If you request access to the information you provided, we will inform you of the existence, use and disclosure of that information as allowed by law, and provide you access to that information.
  2. We assure you that your information is safe and secure. We use industry standards, and physical and technical and administrative security measures to keep your personal information with third parties, except otherwise provided under this Policy.
  3. We store data in password-protected servers with limited access to the employees and other personnel consultants on a need-to-know basis.
  4. We further protect your information from potential security breaches by implementing certain technological security measures including encryption, firewalls and Secure Socket Layer (SSL) technology
  5. Access to your online account on the website /Mobile App is password protected, you are solely responsible for maintaining the confidentiality of that password. To ensure the safety of your personal information, you are advised against sharing your user name and password with anyone.

However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of firewalls and secure server software. By using our Service, you acknowledge that you understand and agree to assume these risks.

7. CHILDREN PRIVACY

We do not knowingly collect or solicit any information from anyone under the age of 13 on the Services provided by Shadhin. In the event that we learn that we have inadvertently collected personal information from a child under the age of 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us at info@shadhinbd.com

8. INFORMATION FROM COOKIES AND WEB BEACONS

A cookie is a small file placed on the hard drive of your computer or mobile device. Cookies are used to track your use of the Shadhin Application/Website in order to provide you with a more personalized user experience, and to allow you to login and begin use of Shadhin Services automatically when you visit the Shadhin Application/Website. Our Application and website use cookies to better your experience while using our Services. Where applicable, our website uses a cookie control system allowing you to allow or disallow the use of cookies on your computer or mobile device. If you wish to deny the use and saving of cookies from our Application or website onto your computer or mobile device, you are advised to take necessary steps from your web browser’s security settings to block all cookies from our website. If you choose to refuse our cookies, you may not be able to use some portions of our Service.

Apart from using cookies the Application and website also uses web beacons which is an often-transparent graphic image often-transparent, usually no larger than a 1×1 pixel that is placed on a web page or in an email that is used to monitor the behavior of the user visiting the Application, website or receiving emails from Shadhin.

9. PERSONAL DATA SECURITY AND CONFIDENTIALITY:

We maintain adequate technical and organizational security measures to protect Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. 

While processing personal data Shadhin shall comply with the following principles of data protection: 

(a) Consent and accountability:

Shadhin shall be accountable to the data subject for the data collected, and the personal data, other than sensitive personal data, process personal data of a data subject with his consent to the processing of the personal data.

(b) Fair and reasonable:

Shadhin shall collect and process such personal data in a fair and reasonable manner that respects the laws of the country.

(c) Integrity: 

Shadhin shall collect, process, hold or use adequate, relevant and not excessive or unnecessary personal data and take reasonable steps to ensure that the personal data is accurate, complete, not misleading and kept up-to-date by having regard to the purpose.

(d) Retention:

Shadhin shall retain personal data for the period authorized by any law made thereunder.

(e) Access to data and data quality: 

Shadhin shall ensure quality of information collected, processed, held or used and a data subject shall be given access to his personal data held and be able to correct that personal data where the personal data is inaccurate, incomplete, misleading or not up-to-date;

(f) Disclosure:

Shadhin shall ensure transparency and participation of the data subject in collection, processing, holding or use of personal data, and subject to this policy. No personal data shall, without the consent of the data subject, be disclosed for any purpose other than the purpose for which the personal data is to be disclosed at the time of collection of the personal data;

(g) Security: 

Shadhin shall observe security safeguards in respect of data and when processing personal data, take proper steps to protect the personal data from any loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction.

10. PERSONAL DATA ACCESS AND CORRECTION: 

Shadhin will provide access to, update and amend, and/or delete the Personal Information in accordance with applicable laws. You can request access to, and have the opportunity to update and amend your Personal Information, and, you can exercise the other rights acknowledged by applicable data protection legislation, including, for example, objection to and blocking of the processing of your Personal Information, by contacting us at info@shadhinbd.com

For security reasons, Shadhin reserves the right to take steps to authenticate the identity of the requesting party before providing access to Personal Information in accordance with this section of the Privacy Policy.

11. VISITORS NOTE:

  1. No Sensitive Personal Data or Information is automatically collected by Shadhin from any visitors of the Websites who are merely perusing or browsing the Website (“Visitor”).
  2. Nevertheless, certain provisions of this Privacy Policy are applicable to Visitors, and Visitors are also required to read and understand the privacy statements set out herein, failing which they are required to leave the Website immediately.
  3. A User will not merely be a Visitor if the User has willingly submitted any personal data or information (including phone numbers, email ids, responses to surveys, etc.) to Shadhin through any means, including email, post, telephone calls, telephonic messaging or through the registration process on the Website. All such visitors shall be deemed to be, and will be treated as, End Users for the purposes of this Privacy Policy, and in which case, all the statements in this privacy policy shall strictly apply to the User.

12. LINKS TO OTHER WEBSITES:

Our service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. This Privacy Policy applies solely to the information collected by us through this Application and the Service. We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. We encourage our users to read the privacy statements of other websites before proceeding to use them.

13. CHANGE OF POLICY:

We may make changes to the Privacy Policy from time to time. We will notify you of any material changes by sending you an email, posting a notice on the home page of the Shadhin App/Site, or posting a notice in your account when you first login after we have made changes. If you receive notification or a change in our Privacy Policy, you must review the new Privacy Policy carefully to make sure you understand our practices and procedures. You may not be able to receive notices from us if your cookies are not set to accept and/or are disabled. In any event, by continuing to use the Shadhin App/Site or any Services after the posting of any changes, you confirm your continuing acceptance of this Privacy Policy together with such changes, and your consent to the terms set out therein.

14. GOVERNING POLICY

The site is operated under the Laws and Regulations of Bangladesh you agree that Bangladesh courts will have jurisdiction over any dispute or claim relating to this Privacy Policy 

15. CONTACT INFORMATION

If you have any questions regarding our website or this Policy, please contact us at info@shadhinbd.com