Privacy Policy

Privacy policy of Lark trading and Finance Ltd

This Privacy Policy (“Policy”) is an electronic record in accordance with the provisions of the Information Technology Act, 2000 and the applicable rules made thereunder. This electronic document does not require any physical, electronic, or digital signature.

This Policy constitutes a legally binding agreement between you and Larktrading and Finance Limited (Larktarding) governing your access to and use of the website and/or mobile application (“Website/App”).

By clicking on the “I Accept” button or by continuing to access or use the Website/App, you acknowledge that you have read, understood, and agreed to be bound by the terms of this Policy. These terms shall be effective from the date of such acceptance and will govern your relationship with Larktrading with respect to your use of the Website/App.

1. Scope of this Privacy Policy

This Privacy Policy governs the following aspects:

  1. The types of information collected from visitors and users, including personal information;
  2. The purpose, methods, and manner of collection, usage, processing, retention, storage, and destruction of such information. For the purposes of this Policy, “Personal Information” shall include any data, documents, or details provided by you to Larktrading, including but not limited to your:
    • Full name
    • Contact number
    • Residential address
    • Date of birth
    • Email address
    • Gender
    • Photograph
    • Occupation
    • Financial information such as bank account details, bank statements, credit or debit card details, credit score, PAN number, Aadhaar number, income tax returns, salary slips, TDS statements, and credit credit information reports
    • Identity and address proof document numbers
    • Login credentials (including user ID and password)
    • Social media activity
    • Any other information or documentation that may be requested by Larktrading from time to time Personal Information includes any and all information received or collected by Larktrading, whether through email, online forms, mobile applications, telephone, facsimile, mail, physical documents, or any other means.

2. What do we collect

The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 defines Personal Information as any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person.

We collect information or personal data/information to provide better experience and services to all our users. We collect the following information or personal data of visitors ("information" or "data" or "personal data"):

  1. When browsing on the Website, the Visitor is not required to provide any Personal Information unless and until you choose to make an Account.
  2. Even if you are not signed up you may provide us information like an email address to receive an update of our services.
  3. When you create your account, you provide your personal information including names, address, mailing address, telephone number, email address, PAN, Aadhar and other financial and personal information. We also collect and store content you create, and content or document you upload.
  4. We also collect information about the browser, apps, and devices you use.
  5. When you are applying for a loan at larktrading, we may ask you to provide access to your Gmail/Facebook/LinkedIn or any other social media accounts. When you give us access, we may collect and store your information through financial related emails, messages, communications for the intended purposes, specially to analyses and understand your creditworthiness, credit profiling, credit pattern, past defaults, reconciliation of Bank Statements, Detection of non-disclosed running /closed loans, unpaid liabilities, criminal and legal cases intimations, and other User's credit-related and financial information and further to verify Banking, loan details, EMI & Financial Transactions, utility bills etc. Such access to information shall in Read Only' mode.
  6. When you access your account through Borrower's Mobile APP, we may collect information from your SMS or call logs, to anal yse and understand your creditworthiness, credit profiling, credit pattern, past defaults, reconciliation of Bank Statements, Detection of non-disclosed running /closed loans, unpaid liabilities, criminal and legal cases intimations, and other User's credit-related and financial information and further to verify Banking Transactions, loan details, Emi & Financial Transactions, utility bills etc, and further to assess social status of the applicant and to ensure ownership of the Mobile No. Such access to information shall in Read Only' mode. All this data from your phone through our app is uploaded on our servers https://api.larktradingfunding.com/. This data uploaded on server is deleted if you loan is rejected or if loan is fully repaid.
  7. Depending on the nature of your inquiry or activities on the website/App we may collect information about your interests, liking of styles themes, mood boards, budgets, etc and professional information through white papers and newsletters you request.
  8. When you use our services, we can also collect information about your location, which can be determined by, among others, through GPS. The types of location data we collect depend in part on your device and accounts settings.
  9. For the purpose of services, to analyse and understand your creditworthiness, credit profiling, credit pattern, past defaults, reconciliation of Bank Statements, Detection of non-disclosed running /closed loans, unpaid liabilities, criminal and legal cases intimations, and other User's credit-related and financial information and further to verify Banking, loan details, Emi & Financial Transactions, utility bills etc., in some circumstances, we may collected your information from publicly accessible sources from example external available links, newspapers, various search engine. We may also collect your information from our trusted partners for the purpose of our services and in the interest of our investors.
  10. Your information may be collected through cookies as provided here in below.

3. Information collected from Borrower Mobile Application/website login

  1. Camera related permissions Permission to access Camera is required so that requisite KYC documents can be easily scanned or captured and thus saving time by allowing us to auto-fill relevant data or so that an audio/video call can be initiated for the purpose of KYC completion. This will ensure that you are provided with a seamless experience while using our application.
  2. Storage related permissions Storage permission is required so that your KYC and other relevant documents can be securely downloaded and saved to your phone.These KYC documents can then be easily uploaded for faster completion of your loan application and disbursal. This will help us to ensure that you undergo a seamless experience on our app.
  3. Location related permissions Background Location related permissions are required to assess serviceability of your loan application. We will pull your location in the background even when the app is not in use unless your loan application has been rejected.This will be used in verifying the current address and expedite completion of your KYC process. It will also help in strengthening security against any unauthorized access to your account. This permission will also be used for providing better customer service and providing customized offers.
  4. Phone related permissions Phone Related Permission is required for Specific Information that is collected and monitored by our app regarding your device including your RAM, Storage, Unique device identifiers like IMEI and mobile network information so as to uniquely identify the devices and to ensure that no unauthorized device acts on your behalf which will help us in preventing frauds. This will also help us in enriching your credit profile and assessing your credit worthiness.
  5. Financial SMS related permissions Financial SMS related permission is required to collect data only regarding Financial SMS. We do not read, collect or store any data regarding your personal SMS/communication. Our app only read, collect or store data of your financial transactional SMS relating to bank transactions, transacting parties' names, a description of the transaction and the amount of the transaction for assessing credit risk and for speedy disbursal.
  6. Installed Application related permissions This Installed Application related permission is required as we collect each installed applications' metadata information which includes the application name, package name, installed time, updated time, version name and version code of each installed application on your device to assess your creditworthiness and provide you with pre-approved customized loan offers.
  7. User Personal Information related permissions This Personal Information Related permission is required to collect user account data which includes email address and user public profile information like name, photo, ASID depending on the social media or networking platform used by you (Such as Google, Facebook etc.) to log-in to the app. This information is required as a part of the registration process and to access our service and is also used to auto-populate relevant fields in the course of our app interface. Our app also collects mobile numbers for verification to check the active SIM status of the device, uniquely identify you and to prevent frauds and unauthorized access.
  8. Phone Contact related permissions Phone contact related permission is required to verify that the references given by the user while applying the loan application form are known references and are saved in the contact list of the borrower. This information will help us in assessing the credit risk and offering speedy disbursal.

4. Larktrading will not share the Personal Information with any Third Party without the Visitors Explicit Consent.


5. How do We Use the Information?

All the information from your phone through our app is uploaded on our servers
We use your information or personal data (intended purposes):

  1. To provide our services and service related purpose such as responding to your queries, and carrying out the transactions you have requested for; enabling you to use the Website/Mobile App; providing you information about services available through website/Mobile App; Resolving glitches on the website /Mobile App including addressing any technical problem;
  2. Maintain and improve our services such as navigating the website, connecting to the potential lenders and carrying out a transaction on the website/Mobile App.
  3. Use Data to analytics and measurement to understand the Borrower/User's creditworthiness, credit profiling, credit pattern, credit score, past defaults, and other User's credit-related and financial information.
  4. Enabling payments and fund transfers with other financial institution.
  5. If you are a Lender/Investor, such information and personal data shall be used for generating Investor/ Lenders Profile.
  6. To communicate or interact with you (E-mail Id, Phone Nos.).
  7. Improve the safety and reliability of our services.
  8. Reconcile Bank statement.
  9. To prevent fraud and misuse.
  10. To protect our interest, the interest of our Investors/Lenders and other users,
  11. Detection of the non-disclosed required information, running or closed loans,
  12. Detection of unpaid liabilities and legal cases.
  13. Enforcing our rights and /or that of the Lender/Investor in case of a Borrower.
  14. For Internal business purpose, such as Data analysis, research, developing new features, enhancing and improving the experience, identifying usage trends, etc.

6. How to Avail the Services?

The User always has the option to not provide information by choosing not to use a particular service or feature. The Personal Information of each Account is protected by a password. The User and larktrading shall take all measures to prevent any unauthorized access to the Account and the Personal Information. larktrading endeavors to safeguard user information to ensure that Personal Information of each Account is kept private; however, larktrading cannot guarantee the security of user Account information.

7. Information and Security

To access and use the full range of services available on the Website and Mobile Application (“Website/Mobile App”), visitors are required to complete an online registration process and create an account (“User” and “Account,” respectively).While browsing the Website/Mobile App as a visitor, you are not obligated to provide any Personal Information unless you choose to register and create an Account.Personal Information collected from users is essential to Larktrading’s operations and business activities.

8. Review, Update, and Deletion

When you are signed in, you can always review, and update information. You can also review and control information saved in your account. You can also always export a copy of the content in your Account if you want to back it up. If you don't want to use our services, you have always option to delete your account with us.

9. Cookies and other Tracking Technologies

  1. larktrading may also collect information regarding the domain and host from which the Visitor accesses the internet, the internet protocol address of the computer or internet service provider, browsing the history, and anonymous Website statistical data to analyze this data for trends and statistics. The Website uses cookie and tracking technology depending on the features offered which are text files collected by a user's web browser ("Cookies"). A cookie is a small text file, that may be used, for example, to collect information about your website activity.
  2. Analytic and Reporting Technologies: Like the operators of most websites, 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 Website/App and larktrading Services are accessed. We also contract with several online partners to help manage, monitor and optimize our Website/App and larktrading Funding and to help us measure the effectiveness of our advertising, communications and how visitors use the Website/App. To do this, we may use web beacons and cookies
  3. Website/Mobile App utilizes cookies and other tracking technology including proprietary and third-party tracking services; Aggregate Cookie and tracking information may be shared with third parties. By accepting this Privacy Policy, the Visitor confirms your consent for larktrading's usage of Cookies and other such technologies. If a Visitor does not wish to accept Cookies from the Website, the Visitor can configure their web browser so that it does not accept Cookies; however, by doing so certain features of the Website may be inaccessible to the Visitor.
  4. Along with receiving information from third parties, larktrading may also collect Personal Information on the Website by information filled in forms or by a Visitor's correspondences with larktrading, by way of e-mail or chat, registering to use the Website, subscribing to any of the financial services or products offered on the larktrading Website. While using the services available on the Website, larktrading may also store information based on the usage history, this includes, but is not limited to, details of the Visitor's subscription, content viewed, event information, clickstream information, and Cookies that may uniquely identify the browser or the Account. larktrading may also collect information about the Visitor from any contact that a Visitor may have with any of larktrading's services or employees, such as, with larktrading's customer support team, in surveys, or through interactions with larktrading's affiliates.
  5. larktrading develops statistics that are helpful to understand how Visitors can use the Website/Mobile App. larktrading uses this information in the aggregate to measure the use of the Website/Mobile App and to administer and improve the same. This statistical data is interpreted by larktrading in its continuing effort to present on the Website/Mobile App, content that Visitors are seeking in a format they find most helpful. The information larktrading collects and analyzes is completely anonymous and is used to improve the services offered on the Website/Mobile App.

10. Sharing of Information;

Larktrading may disclose the information /personal data in the following ways

  1. Larktrading will share the Personal Information internally with employees who are required in the course (and solely for the purpose of) to receive and analyze the information. We will not disclose the Personal Information to any third party without the Visitor's explicit consent unless required to do so by law.
  2. If larktrading is sold to a third party, or larktrading otherwise becomes subject to a merger, consolidation or acquisition, larktrading will transfer the Personal Information to a third party; however, larktrading will ensure that the same degree of care is taken by such third party.
  3. larktrading may also use the Personal Information to deliver information to the Visitor, in some cases, targeted towards new services, rewards, and promotions. The following are some circumstances under which and people with whom larktrading will share the Personal information from time-to-time:
    1. with third parties for verification purposes, credit rating agencies, credit reference companies and with government agencies, including but not limited to the Reserve Bank of India ("RBI") for the cause of inspection or any other legal diligence which may be conducted by it;
    2. To update larktrading's consumer credit database;
    3. with trusted partners who work on behalf of or with us under confidentiality agreements; these entities may use the Personal Information to help larktrading communicate with the Visitor about offers from larktrading and larktrading's marketing partners;
    4. The fact that you have taken loan, amount, the purpose of loan only for the promotion of the website /Mobile App, on the website or Mobile App.
    5. with companies and/or individuals to perform functions on behalf of larktrading (e.g. processing credit card payments, providing user service, data hosting services), and in such circumstances, these companies or individuals will be provided access to only such Personal Information required to fulfill their functions;
    6. to respond to summons, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims;
    7. to share Personal Information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Terms and Conditions, or to respond to civil or criminal subpoenas, or other requests by law enforcement personnel or as otherwise required by law;
    8. from time to time, to reveal general statistical information about the Website and Visitors, such as number of visitors, number and type of services purchased, etc;
    9. . with third parties such as internal service providers that larktrading may use to facilitate or outsource one or more aspects of the business, product and service operations; however, the Visitor shall note that these internal service providers' are subject to confidentiality agreements with larktrading;
    10. with government agencies mandated under the law to obtain information including sensitive personal data or information for the purpose of verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment of offenses.

11. Protection of Information

  1. larktrading takes all steps reasonably necessary to protect against the unauthorized access, use, alteration, disclosure or destruction of Personal Information. Any Personal Information that larktrading collects and stores are protected using appropriate means. Although larktrading is committed to preventing others from unauthorized access to the Personal Information, larktrading shall not be held responsible for any unauthorized access by third parties.
  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. In order to make every effort to ensure that the Visitor's experience at the Website is secure, larktrading uses encryption technology to protect the Visitor against the loss, misuse or alteration of the Personal Information To keep the Personal Information safe, larktrading ensures that sensitive and private data exchanges between the Visitor and the Website takes place over a Secure Sockets Layer (SSL)-secured communication channel, and are encrypted and protected with digital signatures. SSL-secured communication channels are specially designed to protect personal and sensitive information (payment details), which is sent over the internet. We have SSL certificate from World Certificate Authority and secured under 2048 bit SSL Certificate, with 99.9 % Browser recognition.
  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.
  6. larktrading store and process all data relating to its activities and participants on hardware located within India

12. Limitation of Liability

  1. We are not responsible for any breach of security or for any actions or inactions of any third party that receive your personal information
  2. The Visitor agrees that larktrading or larktrading's third party service providers can collect the Visitor's IP address or other unique identifiers. At times, larktrading also uses these identifiers to collect information regarding the frequency with which the Visitor visits various parts of the Website. larktrading, either itself or through affiliates or group companies may combine the Visitor's internet protocol address with other personal information for larktrading's own marketing and for market research purposes, including internal demographic studies, to optimize larktrading's products and services and customize the Website.
  3. The Visitor acknowledges that all discussion for ratings, chat rooms and/or other message or communication facilities (collectively "Communities") are public and not private communications, and that, therefore, others may read the user's communications without the Visitor's knowledge. larktrading does not control or endorse the content, messages or information found in any Community, and, therefore, larktrading specifically disclaims any liability concerning the Communities and any actions resulting from the user's participation in any Community, including any objectionable content. If particular web pages permit the submission of communications that will be treated by larktrading as confidential, that fact will be stated on those pages. By posting comments, messages or other information on the Website, the Visitor grants larktrading the right to use such comments, messages or information for promotions, advertising, market research or any other lawful purpose.
  4. larktrading keeps the Personal Information for only as long as required to fulfill the purpose for which it was collected. If the Visitor wishes to prevent any such usage by larktrading, the Visitor shall inform larktrading immediately. The Visitor can exercise this right at any time by contacting larktrading at compliance@larktrading.in .
  5. Notwithstanding anything contained in this Policy or elsewhere, larktrading/we shall not be held responsible for any loss, damage or misuse of your Personal Information, if such loss, damage or misuse is attributable to a Force Majeure Event. A Force Majeure Event shall mean any event that is beyond the reasonable control of larktrading and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes, lockouts or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, civil disturbances, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, and any other similar events not within the control of larktrading and which larktrading is not able to overcome.
  6. You Acknowledge that the internet is inherently insecure, and larktrading cannot prevent and is not responsible for interception or hacking of information transmitted through this site by unauthorized third parties.

13. Opt-out

  1. Larktrading provides all Users with the opportunity to opt-out of receiving non-essential (promotional, marketing-related) communications. If the Visitor does not want to receive commercial email or other mail from larktrading , he/she/it can opt-out of receiving information by using the "unsubscribe" option in any marketing e-mail or send an email at compliance@larktrading.in.

14. Correction of Errors

  1. The user can get errors corrected in user's personal information by sending an email to the email id i.e compliance@larktrading.in.

15. Third Party Websites

When a Visitor clicks on a Service Site, the Visitor is entering another website over which larktrading has no control and will bear no responsibility. Often these websites including the payment gateway website require the Visitor to enter their Personal Information. larktrading encourages you to read the privacy statements on all such websites. The Visitor agrees that larktrading shall not be liable for any breach of the privacy of Personal Information or loss incurred by the Visitor's use of the Service Sites. This Privacy Policy only governs information collected by larktrading.

16. Changes /Amendments in Policy

larktrading may amend this Privacy Policy from time to time without requiring any consent from anyone. Use of information larktrading collects now is subject to the Privacy Policy in effect at the time such information is used. If larktrading changes this Privacy Policy, the same will be posted on this page so that the Visitor is aware of the Personal Information collected, used and disclosed by larktrading . Any changes to the Privacy Policy will be communicated through the Website. Visitors are bound by any changes to the Privacy Policy when they use larktrading after such changes have been first posted.

17. Severability

If at any time during the currency of this Privacy Policy, any provision, condition, term, stipulation, covenant or undertaking of this instrument is or becomes illegal, void, invalid, prohibited or unenforceable in any respect, the same shall be ineffective to the extent of such illegality or enforceability without invalidating in any manner whatsoever the remaining provisions hereof or thereof.

18. Contact us:

For any questions about this Privacy Policy or the privacy practices of the Website, the Visitor can contact, please e-mail them to compliance@larktrading.in .

19. Grievance Redressal

In accordance with the Act and Rules made there under, the name and contact details of the Grievance Officer are provided below:

Name: Compliance Officer
Address: C-273, Sector-63, Noida-201301, Gautam Buddha Nagar, Uttar Pradesh
Email id: compliance@larktrading.in
Phone No.: 0120-6849500