The Privacy Commitment is an ‘electronic record’ as contemplated under Section 2(t) of the Information Technology Act, 2000 and is published in accordance with the provisions of Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and the Digital Data Protection Act, 2023 and the Digital Data Protection Rules, 2025, as amended or re-enacted from time to time. This Privacy Commitment being an electronic record is generated by a computer system and does not require any physical or digital signature.

Your privacy is important to us. InstaVyapaar owned and operated by Roctogen Services Private Limited takes the privacy of your information seriously. This Privacy Commitment applies to the main website www.instavyapaar.in This Privacy Commitment sets out the way in which we collect, use, disclose, transfer, and store your personal data. You are advised to carefully read the Privacy Commitment before using this or any other platform, application or channels or communicating with us or sharing information/data. InstaVyapaar will not be liable / responsible for any breach of privacy owing to User’s negligence. Please note that our application and other websites may contain links to third party applications / websites which are provided for your convenience. We are only responsible for the privacy practices and security of our own website and application. We recommend that you check the privacy and security policies and procedures of each and every other application / website that you visit.

You represent to us that you are above the age of 18 (eighteen) years and are in contracting capacity to access our App / Website and share your personal data with us.

Please note, if you choose not to provide us with the requested personal data, we will be unable to offer you our products or services.

Definitions

In this Privacy Commitment, the following definitions are used:

1. App / Application: InstaVyapaar is accessible at Google Play and operated by Roctogen Services Private Limited.
2. Data: Information which is accessed by InstaVyapaar owned and operated by Roctogen Services Private Limited pursuant to your visit to the App / Website.
3. Data Protection Laws: Any applicable law relating to the processing of personal Data, including the Information Technology Act, 2000, Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and Digital Data Protection Act, 2023 and the Digital Data Protection Rules, 2025, as amended or substituted.
4. Roctogen Services / us / we: Roctogen Services Private Limited, a company incorporated in India whose registered office is at Gala-2, CTS No. 141, Kuber Chembers, Datta Mandir Road, Malad East, Mumbai – 400097, Maharashtra, India.
5. Website: The website that you are currently using, www.instavyapaar.in, and any sub-domains of this site, unless excluded by their own terms.
6. You: The natural person who accesses the Website.
   
   

Links to other websites

This App/ Website may, from time to time, provide links to websites of divisions, affiliates and portfolio companies of Vartis Platforms Private Limited and other third parties whose privacy practices may differ from those of Roctogen Services Private Limited. If you provide any data to any of those websites, then your data is governed by their respective Privacy Commitments. We have no control over such websites and are not responsible for the content of these apps / websites. This Privacy Commitment does not extend to your use of such apps/ websites. You are advised to read the privacy policy or User Terms and Conditions of such apps / websites prior to using them. For the purposes of this paragraph, third parties include the lenders, namely Innofin Solutions Private Limited  link:https://www.innofin.in/.

Collection of Personal Data or Sensitive Personal Data or Information

InstaVyapaar may for the purpose of rendering its services, collect personal information such as:

1. Name, gender, date of birth, marital status
2. Residential / correspondence address, mobile number, email address or other contact information;
3. Identification Documents, Aadhaar details, PAN, KYC status, signature and photograph;
4. Bank account or other payment instrument details; or
5. any other detail for providing services.

In addition to the personal information and in order to provide the services to you, InstaVyapaar may also collect your Aadhaar and signature solely for completing the account opening procedures and authenticating your transactions. The act of providing your Aadhaar is voluntary in nature.

We may also infer your country of location from the IP address you have used to access our App / Website.

We may further collect the following personal data, either through the mobile application or other relevant app/website. This information will further be processed, stored and shared with InstaVyapaar to the partnered Regulated Entities to enable lending options for the borrowers. Permissions to these settings may be essential for adequate running of the relevant app/website and can be managed through the respective User device’s controls. These include:

1. Phone
2. Camera
3. Location
4. SMS

We may also collect, store and process information which is voluntarily provided by you vide emails, letters, your interactions with customer care, or messages. We may also collect additional information at other times, for example, when you provide feedback(s), or post on the  app/website, respond to surveys, or communicate with us. 

We also collect information automatically such as device information like device ID, device model etc. and other unique identifiers; advertising identifiers, such as those found on mobile devices and tablets, devices that include identifiers; and information collected via the use of cookies and other technologies.

All personal data that we collect about you will be recorded, used, and protected by us in accordance with applicable data protection legislation and this Privacy Commitment. We may supplement the information that you provide with other information that we obtain from our dealings with you or which we receive from other organizations, for instance, our affiliates.

InstaVyapaar will continuously endeavour to ensure that personal Data shall be used in line with all applicable data protection laws. Your information will be kept secured with restricted access according to the ‘need to know’ principles.

InstaVyapaar or its authorized agents shall not retain or store that information for longer than is required for the purposes except when the information may lawfully be used or is otherwise required under any other law for the time being in force.

The information collected shall be used for the purpose for which it has been collected.

By agreeing to avail of the service offered by InstaVyapaar you have agreed to the collection and use of your Sensitive Personal Data or Personal Information by InstaVyapaar. For availing these services, we may seek certain essential accesses for adequate running of the App / Website.

Use of Personal Data

We use your personal data for the following purposes:

1. to administer and provide products and services you request or have expressed an interest in;
2. to perform credit risk assessment which enables us to determine your risk profile and to provide you with the appropriate credit analysis to enable you to rake financial facilities from the Regulated Entities (financial institutions) and other service providers;
3. for fraud screening and prevention purposes and to protect Roctogen Services’ legal rights and to comply with its legal obligations;
4. for record keeping purposes, to comply with laws and regulations, and to comply with other legal processes and law enforcement requirements;
5. to carry out market research so that we can improve the products and services we offer;
6. to track your activity on our App / Website;
7. to create an individual profile for you so that we can understand and respect your preferences;
8. to personalize and improve your experience on our App / Website and allow you to utilize its features by granting us access to information from your device;
9. to personalize and/ tailor any communications that we may send you;
10. for profiling purposes to enable us to personalize and/or tailor any marketing communications that you may consent to receive from us;
11. to inform you about important details like change in terms, conditions and policies and /or other administrative information important to meet your interests;
12. to address your requests and queries and manage your relationship with us;
13. to access your eligibility for our products or services and provide you with such products or services which you may have shown interest in or requested for;
14. to perform activities such as data analysis, audits, usage trends to determine the effectiveness of our campaigns and as input into improving products and services;
15. for security and business continuity and risk management;
16. for system or product development and planning, audit and administrative purposes; or
17. to meet the legitimate interests to be pursued by InstaVyapaar.
    
    

Cookies

When you register with or view our App / Website, our servers automatically record certain information that your web browser sends whenever you visit our website. The kind of information that is gathered automatically includes the type of browser you are using (e.g. Internet Explorer, Firefox, Google Chrome), the type of Operating System you are using (e.g. Windows or Mac OS) and the domain name of your internet service provider, the date and time of your visit and the pages on our website. We sometimes use this information to improve our App / Website design, content and primarily to give you a better browsing experience.

Further, Cookies let InstaVyapaar store information about your preferences, and passwords and allow you to move to different pages of our secure App / Website without having to re- enter your password information.

This Privacy Commitment is not intended to and does not create any contractual or other legal rights in favour of any user or viewer of this App / Website or on behalf of any other party. However, users and viewers are informed that by using the App / Website, they are deemed to have consented to the collection and use of information by InstaVyapaar

If you prefer to restrict, block, or delete cookies from this App / Website, you can use your browser to do this. Each browser is different, so check the ‘Help’ menu of your particular browser to learn how to change your cookie preferences. If you choose to disable all cookies, we cannot guarantee the performance of our App / Website and some features may not work as expected.

Rights with respect to Data

You have the right to tell us if you:

1. would like to confirm whether the company processes data about you;
2. would like to access your data;
3. would like to correct or update your personal data;
4. would like to port your data or would like a copy of the personal data which we hold about you;
5. would like to delete your personal data in our records;
6. would like to withdraw a consent provided earlier.
   
   

Prohibited Actions

While accessing, visiting or using our application website, you agree not to, by any means including but not limited to hacking, cracking or defacing any portion of the website or application, indulge in illegal or unauthorized activities including the following:

1. Restrict or inhibit any authorized user from using application or website,
2. Use the application or website for unlawful purposes,
3. Harvest or collect information about application or website’s users without their express consent,
4. “Frame” or “mirror” any part of the application or website without our prior authorization,
5. Engage in spamming or flooding, transmit any software or other materials that contain any virus, time bomb, or other harmful or disruptive component,
6. Remove any copyright, trademark or other proprietary rights notices contained in the application or website,
7. Use any device, application or process to retrieve, index, “data mine” or in any way reproduce or circumvent the navigational structure or presentation of the application or website, and

1. Permit or help anyone without access to the application or website to use the application or website through your username and password or otherwise.

You can visit this Website without telling us who you are and continue to access this Website anonymously.

Security

We are to ensure that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

We understand how you care about the privacy and the security of your personal information, which is why we are to respect and protect your privacy and your information shared with us from any unauthorized access or loss. The database is stored on the servers secured behind a firewall and access to these servers is password protected and is strictly limited.

In order to make every effort to ensure that the Users experience at the app/website is secure, Company uses encryption technology to protect the Users against the loss, misuse or alteration of the Personal Information.

However, in this digital era, the transmission of information via the internet is never completely impenetrable. Hence, Users should also take requisite steps to protect their personal information against any unauthorized access. Such steps include choosing a strong password, signing off after using a shared device, and keeping your log-in details, especially your password, private. InstaVyapaar not be held responsible for any lost, stolen, or information or for any activity on your account via unauthorized password usage. Further, InstaVyapaar disclaims all liability for the breach of any of the User’s data in the event the said User fails to follow or knowingly breaches the below mentioned guidelines for access.

Advertising

When we present information to our advertisers to help them understand our audience and confirm the value of advertising on our app/website, it is usually in the form of aggregated statistics on traffic to various pages/ content within our app/website. We use third-party advertising companies to serve ads when you visit our app/website. These companies may use information about your visits to this and other websites or applications, in order to provide advertisements about goods and services of interest to you.

General

If any court or competent authority finds that any provision of this Privacy Commitment (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Commitment will not be affected.

Changes to this Privacy Commitment

InstaVyapaar reserves the right to change this Privacy Commitment as it may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the App / Website. You are deemed to have accepted the terms of this Privacy Commitment on your first access or use of the App / Website following the alterations to this Privacy Commitment, if any.

Governing Law and Jurisdiction

The User Terms and Conditions of this Privacy Commitment shall be governed by the laws of the Republic of India and the courts at Mumbai, Maharashtra, India shall have exclusive jurisdiction to resolve any disputes with respect to implementation, interpretation or breach to the terms hereof.

Grievance Officer

In case of any complaints or grievances, or if you have any questions about this Privacy Commitment, you may contact the Grievance Officer at grievance@instavyapaar.in.  Details of our Grievance Redressal Officer is: Gala-2, CTS No. 141, Kuber Chembers, Datta Mandir Road, Malad East, Mumbai – 400097, Maharashtra, India.