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Policies

Digital Lending
Policy

Naveen Finance Pvt. Ltd. is committed to complying with the RBI Digital Lending Guidelines and implementing responsible, transparent, and customer-centric digital lending practices.

This policy governs the Company's digital lending operations, customer consent framework, disclosure practices, data privacy, and recovery standards applicable to all digital loan products and services.

Digital Lending Channels

Naveen Finance operates digital lending activities through the following authorized and regulated channels:

Company website and web portals
Mobile applications (authorized platforms only)
Digital onboarding systems
API-based integrations with Lending Service Providers (LSPs)
eKYC and eSign-enabled platforms

Loan Disclosures

Prior to execution of any digital loan agreement, customers are provided with the following disclosures:

Key Fact Statement (KFS) summarizing all key loan terms
Annual Percentage Rate (APR) disclosure
Processing fees, charges, and applicable taxes
Repayment schedule and EMI details
Penal charges for late payment and bounce charges
Foreclosure and prepayment terms
Digital sanction letter and loan agreement
Customer support and grievance redressal details

Customer Consent Framework

Customer consent is the foundation of responsible digital lending. The Company follows the following consent principles:

Explicit Consent

Customer consent is obtained explicitly before any data collection, sharing, or processing. Pre-checked boxes or default consent are not used.

Purpose Limitation

Data collected is used only for the stated purpose and is not used for unrelated activities without additional consent.

Consent Revocation

Customers retain the right to revoke consent for data sharing with third parties, with operational impact disclosed transparently.

Informed Consent

Customers are informed in clear and plain language about the nature and purpose of data collection before consenting.

Data Privacy Commitments

Naveen Finance is committed to protecting customer data in compliance with applicable data protection laws and RBI Digital Lending Guidelines:

Minimal data collection — only information necessary for lending activities is collected
No unauthorized access to mobile device contacts, location, media, or other device data
Explicit consent obtained before accessing any device permissions
Customer data is not shared with unauthorized third parties
Secure digital onboarding with encrypted data transmission
Access-controlled storage systems with role-based permissions
Customer data is not sold or monetized without explicit consent

Recovery Practices & Prohibited Activities

All recovery activities comply with RBI guidelines and the Company's Fair Practices Code. The following practices are explicitly prohibited:

Permitted Recovery Standards

Recovery agents identify themselves with proper authorization credentials
Contact is made only during permitted hours (8:00 AM to 7:00 PM)
Harassment, intimidation, or coercive communication is strictly prohibited
Customers' family members, employers, or neighbors shall not be contacted for recovery
Public disclosure of borrower default information is not permitted
Multiple or excessive communication attempts are not made without customer request

Prohibited Practices

Accessing device contacts, photos, or location data without explicit consent
Sending threatening or abusive communication to borrowers
Contacting unauthorized third parties regarding borrower default
Public naming and shaming of borrowers on social media
Using fake caller IDs or impersonating regulatory authorities
Charging unauthorized fees or deductions not disclosed in loan agreement
Disbursing loans through third-party accounts not linked to the borrower

Grievance Mechanism

Customers experiencing issues with digital lending services may contact our grievance team at grievance@naveenfinance.in. If unresolved within prescribed timelines, customers may escalate to the RBI Integrated Ombudsman through the CMS portal at cms.rbi.org.in.