Introduction

  • Clearly identify your company and domain (e.g., “This Privacy Policy (hereinafter ‘Policy’) applies to the services provided by [prime lone hub], through primeloanhub.in (hereinafter ‘we’, ‘us’ or ‘Website’).”)

  • State the effective date and note that users should review it periodically for updates.

Data Controller / Data Fiduciary Details

  Name and contact details of your organization.

    • If applicable, include the Data Protection Officer’s (DPO) contact (email/phone) for user queries and requests.
      Optional, but strongly advised in anticipation of DPDP Act obligations.

Types of Data Collected

  • Personal Data: e.g., name, email, phone number, address, income, credit score, loan preferences, etc.

  • Sensitive Personal Data: financial details, KYC documents like Aadhaar, PAN, etc.

  • Device and usage data: IP address, cookies, browsing behavior.

  • Specify if you collect data from third-party sources (credit bureaus, analytics tools).

Purpose of Collection & Legal Basis

  • Examples:

    • To offer loan comparison, generate leads, match with lenders, or pre-fill loan applications.

    • For internal analytics, improving user experience, notifications.

  • Clarify legal basis: user consent, legitimate interest, contractual necessity, etc., per DPDP principles

Consent

  • Explain how you obtain explicit consent (e.g., opt-in forms).

  • Describe how users can withdraw consent—via email or clear interface options.

Use and Disclosure of Information

  • Data may be shared with:

    • Loan partners, financial institutions, credit bureaus, or third-party service providers—strictly for loan facilitation or user-approved purposes.

    • Legal authorities if required by law.

  • All third parties are bound by confidentiality agreements.

Cookies and Tracking Technologies

  • Describe use of cookies (e.g., preferences, login sessions, analytics).

  • Users can manage cookie preferences via browser or website settings.

Data Retention

  • Provide rationale and timelines (e.g., retain data until purpose is fulfilled, or as required by law, then delete or anonymize)

  • Align this with DPDP obligations on retention limitation

Data Security Measures

State your practices: encryption (in transit/at rest), access control, regular audits, secure storage, etc.

User Rights

  • nform users of their rights under DPDP:

    • Access, correction, erasure, portability, withdraw consent

    • Lodge grievances or escalate to the Data Protection Board

  • Provide instructions on how to exercise these rights (e.g., email contact).

Cross-border Data Transfers

If applicable, note precautions for cross-border transfers:

  • Allowed only to countries with adequate protection or under contractual safeguards.

Children’s Data

  • If not intended for users under 18, state “Our services are not directed at minors. We do not knowingly collect personal data of children under 18.”

  • Alternatively, require guardian consent if minors may access.

Updates to Policy

  • Reserve the right to modify the Policy (e.g., due to legal changes or business needs).

  • Mention how users will be informed (e.g., site notice, email).