3.1 | Product Transparency
- Disclosure of terms, conditions and obligations to customer
- The Member should strive to make sure that detailed terms and conditions of the financial product and services offered are made available to the customer.
- A sanction letter or Sanction Intimation detailing the Loan/Credit Facility is issued to the customer by Lender before execution of the Loan Agreement.
- A loan agreement containing detailed outlines of the obligations and commitments of the customer and commitments of the lender in the relationship should be provided to the customer.
- The Customer must be clearly communicated that a loan is being granted which is to be repaid in certain time frame, failing to do so will have consequences in terms of Credit Bureau reporting and potential legal action on the event of default.
- Efforts should be taken to make customer understand the ultimate lender and who would be the Technology Partner. In the event the Member is not the lender, the customer should understand the role and responsibility of the Member in the process and transaction relating to the financial product and services.
- The customer must be clearly communicated the Grievance Redressal Mechanism including forums he can approach.
- Disclosure of all Costs to Customers
- The Member must unambiguously list all costs and fees related to the product or service offered, including all upfront fees, processing fees, interest costs, insurance costs, registration fees, provisions, re-arrangement fees, late fees, prepayment fees or penalties and any other costs charged to the customer.
- The description of all costs, including any conditional or default costs and expenses, must be explicitly provided in a manner that any customer can easily understand.
- The Member must provide examples of the costs to the customer, including any contingent or default costs, in INR format specific to the financial service or product offered, so that the customer understands exactly all such costs.
- The Member must provide a repayment schedule with detailed repayment information and due dates in a clear manner.
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3.4 | Data Usage and Sharing
- The Member must follow a consent-based architecture for data capture with informed consent provided by the customer following a detailed explanation of the data being captured and used (including sharing of such data with third parties). The Member shall preserve such digital records of customer consent(s) as proof of informed consent.
- The Member is required to practice good faith in the collection, storage, use and sharing of personal data of customers.
- Without limiting the generality of the above, Members shall not:
- intentionally request personal data from a customer even though there is no service that can be provided to a customer;
- intentionally collect personal data irrelevant to the services that will be provided to the customer by the Member;
- collect personal data outside the data that has been agreed to be given by the customer;
- use personal data for purposes that have not been notified or purposes that are different from what was previously notified to the customer;
- collect and store customer’s personal data even though the Member or any person authorized by the Member to collect, process or store such personal data does not yet have a reliable system or processes to carry out such activities or protect such data;
- sell personal data of customers to third parties without explicit consent from the customer;
- share such personal data with third parties other than for purposes consented to by the customer;
- use the personal data in any manner which is likely to cause physical harm or injury to any customer, their family member or any person associated with the customer.
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