Privacy Policy

1. WHAT INFORMATION DO WE COLLECT?

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Names
• Phone numbers
• Email addresses
• Mailing addresses
• Job titles
• Usernames
• Passwords
• Contact preferences
• Contact or authentication data
• Billing addresses
• Debit/credit card numbers

Sensitive Information: We process the following information:

• KYC Information: PAN, Aadhaar, Voter ID, Driving License.
• Financial Information: Bank account details, salary slips, bank statements, income proofs.
• Employment Details: Employer name, occupation, monthly income.
• SMS access for OTP/transaction security
• Microphone access for Video KYC
• Explicit mention of Digilocker, CKYC, UIDAI integrations
• Installed apps check (common in lending apps for risk scoring)
• Credit Information: Credit bureau reports (CIBIL, CRIF, Experian, Equifax).

Additional Information We May Collect

To provide seamless lending services and comply with regulatory requirements, we may request the following additional permissions and data access:

• SMS Access:Limited access to SMS messages for reading OTPs and detecting financial transactions, solely for fraud prevention and loan eligibility checks. We do not read or store personal messages.
• Microphone: One-time access for Video KYC verification, as required under RBI KYC guidelines.
• Contacts (Optional): Access to contacts may be requested if you choose to invite friends or use referral/reward programs. This is entirely optional.
• Digilocker and CKYC:We may fetch your officially valid documents from Digilocker or CKYC Registry to complete KYC formalities quickly.
• Installed Applications (Optional):We may collect a list of installed apps only for risk assessment, fraud detection, and creditworthiness analysis. We do not access personal data from these apps.

Payment Data: We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument.

Application Data: If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Geolocation Information: We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Access: We may request access or permission to certain features from your mobile device, including your mobile device's bluetooth, calendar, camera, microphone, reminders, contacts, sensors, social media accounts, sms messages, storage, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Data: We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.
• Push Notifications: We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

1.a Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. The information we collect includes:

• Log and Usage Data: Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports sometimes called "crash dumps", and hardware settings).
• Device Data: We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data: We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.
• Selfie or Photograph: verification

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
• To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below.
• To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.
• To post testimonials: We post testimonials on our Services that may contain personal information.
• To protect our Services: We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To administer prize draws and competitions. We may process your information to administer prize draws and competitions.
• To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.
• To identify usage trends: We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
• To assess creditworthiness using information from credit bureaus.
• To verify identity and perform KYC as per RBI guidelines.
• To disburse loans and manage repayment schedules.
• To report repayment history to credit bureaus.
• To engage third-party collection agencies for recovery, if required.
• To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

Information Sharing With Regulators and Infrastructure To ensure compliance with applicable laws and smooth functioning of lending services, We may need to share your personal information in the following situations:

• Credit bureaus (CIBIL, CRIF, Experian, Equifax).
• NBFC/lending partners for loan disbursal.
• Payment gateway providers for loan repayments.
• Collection and recovery agencies (if required).
• Cloud hosting, SMS, email, and communication providers.
• Regulatory Authorities: Reserve Bank of India (RBI), UIDAI, NPCI, and other statutory bodies as required.
• KYC Infrastructure: Central KYC Registry (CKYC), Digilocker, and other authorized KYC service providers.
• Payment Systems: NPCI and payment rails such as UPI, NACH, NEFT, and IMPS for disbursements and repayments.
• Account Aggregators: For retrieval of your financial data, only with your consent, to assess loan eligibility and repayment capacity.

We may share your information with Google Analytics to track and analyze the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: Loan-related data will be retained for a minimum of 5–8 years after loan closure or as mandated by RBI regulations, even if the user account is deleted.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). Retains even beyond customer relationship if required for compliance or legal claims.No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

Our Security Practices

We implement advanced technical and organizational safeguards to protect your information:

• Data in transit is encrypted using TLS 1.2 or higher.
• Data at rest is secured with AES 256-bit encryption.
• Strict access control, continuous monitoring, and periodic security audits are conducted.
• In the event of a security breach, we will follow our Cyber Crisis Management Plan and notify CERT-In and RBIwithin the legally mandated time.

7. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to minors.

Our services are strictly for individuals aged 18 and above, as required by RBI regulations. If we find that an account belongs to a minor, it will be immediately terminated, and all associated data will be deleted. We do not knowingly collect, store, or process personal data from individuals under 18 years of age. If we become aware that a minor has provided their information, we will take immediate steps to delete such data. Parents or legal guardians who believe their child has provided us with personal information should contact us at [support email] for data removal.

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Users cannot request deletion of credit bureau data reported by us, since we are legally required to report loan history to bureaus.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update your user account.
• Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

In Short: We currently do not respond to DNT signals as no standard has been established.

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

10. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

We will update this Privacy Policy periodically to reflect changes in Indian laws, including the DPDP Act, IT Act, and RBI guidelines. Users will be notified of major policy updates via email or in-app notifications.

11. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

In Short: You may request access, updates, or deletion of your personal information as permitted by law.

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit: contact@nestapp.in

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

In Short: You can contact us by email or post if you have questions or concerns about this Privacy Notice.

If you have questions or comments about this notice, you may contact us by post at:

13. GRIEVANCE REDRESSAL & NODAL OFFICER DETAILS.

In Short: In accordance with the Digital Personal Data Protection Act (DPDP Act) and Section 43A of the Information Technology Act, we have appointed the following Grievance Officer & Nodal Officer to address data protection and user-related concerns:

Grievance Officer

• Name: Arkot Mitesh
• Designation: Grievance Officer
• Email: grievance@nestapp.in
• Phone: +91 88857 32267
• Address: No 61, Before National Highway, Kondayapalem Road, Nellore, Andhra Pradesh, India, 524003

Nodal Officer

• Name: Mohith Reddy
• Designation: Nodal Officer
• Email: nodal@nestapp.in
• Phone: +91 95054 00666
• Address: No 61, Before National Highway, Kondayapalem Road, Nellore, Andhra Pradesh, India, 524003

We commit to acknowledging your grievance within 24 hours and resolving it within 15 working days, as per RBI norms.