Privacy Policy

1. Nature of the Platform and Operating Role

1.1 Role of Super Ku

Super Ku operates solely as a technology platform and Loan Service Provider (“LSP”). Super Ku provides the digital interface and technology services through which eligible users may submit loan applications to the regulated lending partner.

1.2 Regulated Lending Partner

The regulated lending entity (“RE”) associated with Super Ku is PAROPKAR DISTRIBUTORS PRIVATE LIMITED, a Non-Banking Financial Company registered in India.

User Eligibility Declaration: By accepting this Privacy Policy, you represent that you are an Indian citizen residing in India, are at least 18 years of age, and possess the legal capacity to enter into a binding agreement under the Indian Contract Act, 1872.

2. Information We Collect

We follow the principles of necessity, proportionality, and data minimization. We seek to collect only the information that is reasonably necessary for processing loan applications, completing identity verification, assessing risk, complying with legal obligations, and providing our services.

2.1 Information Submitted by You

To verify your identity, complete KYC procedures, evaluate your loan application, and provide financial services, we may collect the following categories of information:

• Personal and demographic information: Full name, date of birth, gender, and marital status.
• Contact information: Current residential address, valid mobile phone number, and email address.
• Identity and regulatory documents: Aadhaar-related information, PAN card details, and other information required for lawful KYC verification.
• Financial and banking information: Bank account number, account holder information, and IFSC code required for loan disbursement, repayment processing, and account verification.
• Loan application information: Requested loan amount, repayment period, income information, employment or occupation details, and other information submitted as part of your application.

2.2 Application Permissions

We request your explicit permission before accessing specific device features. You may refuse or revoke optional permissions through your device settings; however, certain features that depend on those permissions may become unavailable.

3. How We Use Your Information

We process your personal information only for lawful, disclosed, and necessary purposes, including:

• Loan facilitation: To receive and process your loan application and transmit necessary information to the regulated lending partner for assessment and approval.
• Identity and KYC verification: To verify your identity, validate submitted documents, and comply with applicable KYC obligations.
• Credit and risk assessment: To assist the lending partner in evaluating your financial status, creditworthiness, identity consistency, and repayment capacity, including verification through authorized credit information companies or other legally permitted sources.
• Regulatory compliance: To comply with applicable anti-money laundering (“AML”), KYC, fraud prevention, financial reporting, recordkeeping, and regulatory requirements.
• Loan servicing: To facilitate loan disbursement, repayment processing, payment reconciliation, account management, and customer support.
• Service communications: To send one-time passwords, application updates, payment reminders, loan documents, account notifications, security alerts, and important policy or service updates.
• Fraud prevention and platform security: To detect suspicious activity, prevent identity theft, investigate misuse, protect users, and maintain the security and integrity of the Platform.
• Complaint resolution: To respond to customer questions, privacy requests, grievances, and disputes.

4. Data Sharing and Third-Party Disclosure

We treat your personal information as confidential. We do not sell or rent your personal information to unauthorized third parties. Your information may be shared only when reasonably necessary and legally permitted, including in the following circumstances:

4.1 Regulated Lending Partner

Information required to process and service your loan may be shared with PAROPKAR DISTRIBUTORS PRIVATE LIMITED. The lending partner may use the information for loan assessment, KYC verification, approval, disbursement, servicing, collection, compliance, and other lawful lending-related purposes.

4.2 Authorized Service Providers

We may share limited information with carefully selected service providers that support our operations, including:

• SMS and one-time-password service providers;
• Identity verification and KYC service providers;
• Electronic signature and Aadhaar eSign service providers;
• Bank account verification and payment gateway providers;
• Cloud hosting, data security, and technical support providers;
• Credit information companies and legally authorized risk assessment providers.

Such service providers may process information only for the contracted purpose and are required to comply with applicable confidentiality, security, and data protection obligations.

4.3 Legal and Regulatory Disclosure

We may disclose your information when required by applicable law, a lawful court order, a regulatory direction, or a request from an authorized government or law enforcement agency, including the Reserve Bank of India or other competent authorities.

4.4 Corporate Restructuring

If Super Ku or the relevant business operations are involved in a merger, acquisition, restructuring, transfer, or sale of business assets, personal information may be transferred to the successor entity, subject to applicable law and continued protection under appropriate privacy and security safeguards.

5. Data Storage, Security, and Localization

5.1 Data Localization

In accordance with applicable Indian regulatory requirements, personal, financial, transactional, and technical data collected through Super Ku is stored on secure servers located within India, where required by law or regulatory direction.

5.2 Security Measures

We implement reasonable administrative, organizational, and technical safeguards designed to protect your information against unauthorized access, disclosure, alteration, misuse, loss, or destruction.

These safeguards may include:

• SSL/TLS encryption for information transmitted over networks;
• Encryption of sensitive information stored within our systems;
• Role-based access controls and access authorization procedures;
• Activity logging and security monitoring;
• Periodic vulnerability assessments and security reviews;
• Confidentiality obligations for employees and service providers.

Although we take reasonable precautions, no online platform, electronic transmission method, or storage system can be guaranteed to be completely secure.

5.3 Data Retention

We retain personal information only for as long as necessary to provide the requested services, maintain an active loan account, resolve disputes, enforce agreements, prevent fraud, or comply with applicable legal and regulatory obligations.

Certain KYC, loan, and transaction records may be retained for the period required under applicable laws, including financial, anti-money-laundering, taxation, audit, and recordkeeping requirements. When the applicable retention period expires and the information is no longer required, it will be securely deleted, anonymized, or otherwise disposed of in accordance with our internal procedures and applicable law.

6. User Rights and Consent Management

Subject to applicable law and regulatory restrictions, you may exercise the following rights regarding your personal information:

6.1 Right to Withdraw Consent

You may withdraw your consent to optional data access or processing at any time by changing your device permissions or contacting us.

Withdrawal of consent will not affect processing that was lawfully completed before the withdrawal. It may also prevent us from continuing to provide features or services that require the relevant information.

Where you have an active or outstanding loan, Super Ku and the regulated lending partner may continue to retain and process information required to service the loan, recover lawful amounts due, comply with regulatory requirements, and maintain legally required records until the obligation has been fully discharged and the required retention period has expired.

6.2 Right to Access and Correction

You may request access to information associated with your account and ask us to update or correct inaccurate, incomplete, or outdated personal information, subject to identity verification and applicable law.

6.3 Right to Request Account Deletion

After all outstanding loan obligations have been fully settled, you may request the closure and deletion of your Super Ku account.

Certain information may continue to be retained where required for KYC, financial recordkeeping, fraud prevention, dispute resolution, regulatory inspection, or other legal purposes.

6.4 Right to Raise a Grievance

You may contact us regarding any concern about the collection, use, storage, disclosure, correction, or deletion of your personal information.

7. Grievance Redressal Mechanism

We have established a grievance redressal mechanism to address privacy, account, and loan-service-related concerns in a timely and appropriate manner.

When submitting a request or complaint, please provide your registered mobile number, a clear description of your concern, and any relevant supporting information. We may request additional information to verify your identity before processing a privacy-related request.

8. Updates to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in applicable laws, Reserve Bank of India guidelines, regulatory requirements, technology, security practices, lending arrangements, or our internal procedures.

The revised Privacy Policy will be made available within the Platform or through another appropriate communication method. Where legally required, we will obtain renewed consent before processing your information for a materially different purpose.

Your continued use of Super Ku after an updated Privacy Policy becomes effective indicates that you have reviewed the revised policy, subject to any consent requirements imposed by applicable law.