Privacy Policy
This Privacy Policy ("Policy") describes how Growise Fort Limited ("Growise", "we", "our", or "us") collects, uses, processes, and discloses information in connection with its services. We are committed to handling personal data responsibly and with appropriate safeguards, ensuring transparency, confidentiality, and compliance with applicable data protection laws and regulations, as well as generally accepted industry standards for information security (collectively referred to as the "Law").
This Policy applies only to the data processing activities carried out by Growise. It explains how we manage information that we collect directly. It does not address the practices of third parties that may independently collect or process your information. Likewise, this Policy does not apply to external websites, platforms, products, or services that are not operated or controlled by Growise. We recommend that you review the privacy notices of such third parties to understand how they handle your information.
When you access or use our website or mobile application ZaelCash ("ZaelCash", the "App", or collectively the "Platform"), submit a loan application, or otherwise use any services provided by us (collectively referred to as the "Products and Services", which include the Platform), you may provide us with certain personal information. We recognize the importance of that trust and are committed to protecting your data.
This Policy is intended to clearly explain what types of information we collect, how that information is used, and the rights you may have regarding your personal data.
Please review this Policy carefully so that you understand how we collect, use, and protect the information associated with your use of our services.
1. WHY DO WE COLLECT YOUR INFORMATION?
To access certain features of our Platform, you may be required to create an account. In accordance with our Terms of Service, registered users may become eligible to apply for and receive loan services offered under our Products and Services.
In order to enable these services, we must collect and process certain personal information from you. Such information is necessary for identity verification, account management, credit evaluation, and for the proper delivery of the Products and Services we provide through the Platform.
2. WHAT INFORMATION DO WE COLLECT?
2.1 Personal information you provide to us
We collect personal information that you voluntarily submit to us. This may occur when you create an account on the Platform, request information about our company or the Products and Services we offer, participate in activities available on the Platform, submit a loan application, or communicate with us through other channels.
The categories of personal information we collect depend on the nature of your interaction with us, the features you choose to use, and the services you request. Such information may include, but is not limited to: your full name, date of birth, marital status, current residential address, phone number(s), email address, emergency contact details, self-reported income information, employment status, and other related details necessary to provide our services.
You are responsible for ensuring that the personal information you provide is accurate, complete, and up to date. If any of this information changes, you should promptly inform us so that our records remain accurate.
2.2 Information collected automatically
When you access or use the Platform, certain technical information may be collected automatically. This data does not directly identify you as an individual but may include information related to the device you use and how the Platform is accessed.
Examples of such information include your IP address, device name, device type, mobile network information, usage timestamps, and other technical or diagnostic data. This information is primarily used to maintain system security, support the functionality of the Platform, and perform internal analytics, monitoring, and reporting.
2.3 Information collected through device permissions on our Platform
When you use the Platform, we may request specific device permissions in order to access limited categories of information. These permissions allow certain features to function properly and help us maintain service security and reliability.
Device Information
We may collect certain device-related information such as device model, operating system version, device identifiers permitted by the iOS system, network type, and general device configuration. This information is used to maintain system security, ensure service compatibility, and assist in fraud prevention.
Approximate Location
With your permission, we may collect approximate location information through location services. This may include general geographic data derived from Wi-Fi networks or IP-based location signals. Such information helps verify service availability in your region, support compliance with regulatory requirements, and detect potential fraudulent activities. We do not continuously track your location, and location information is only collected when necessary for service functionality.
Advertising Identifier (IDFA)
With your authorization through Apple's App Tracking Transparency framework, we may collect your device's advertising identifier, known as the Identifier for Advertisers (IDFA). This identifier may be used to measure application performance, attribute marketing campaigns, and detect fraudulent or abnormal activity. The identifier is used only for analytics and attribution purposes and may be shared with authorized analytics or marketing service providers in accordance with applicable data protection agreements.
Calendar
With your explicit consent, the Platform may access limited calendar information, including event titles, dates, and times. This information may be used to better understand financial commitments as part of credit assessment and to create repayment reminder events within your calendar. Calendar data is used only for these purposes, transmitted securely, and is not used for advertising or marketing. You may revoke this permission at any time through your device settings.
Application Interaction
We collect data relating to how users interact with the Platform, such as taps, swipes, navigation events, and error logs. This information helps us diagnose technical problems, refine product functionality, and improve the overall user experience.
Diagnostics and Performance Data
We may collect certain diagnostic information related to the operation of the application, such as launch records, crash reports, performance metrics, error logs, and device resource usage (for example battery consumption). This information helps us analyze system performance, maintain application stability, and enhance service reliability.
2.4 Transmission and protection of personal information
All personal and sensitive information collected through the Platform is encrypted during transmission and securely transferred to our servers via HTTPS at https://interface.growisefortglo.com.
Access to this information is restricted to authorized personnel and trusted service providers who are bound by confidentiality obligations and data protection requirements. We do not sell, lease, or otherwise disclose your personal information to unrelated third parties.
3. HOW DO WE USE YOUR INFORMATION?
3.1 Purposes for processing personal information
We process personal information obtained through the Platform for various operational and business purposes. Depending on the situation, such processing may rely on our legitimate business interests, the need to perform or enter into a contract with you, your consent, or our obligations under applicable laws and regulations. The purposes for which we use the information we collect include the following:
Know-Your-Customer (KYC) and identity verification
To deliver our Products and Services, we must collect certain personal data and verify your identity as part of our customer onboarding and verification procedures.
Loan processing, disbursement, and repayment management
After submitting the required information and completing verification, you may apply for a loan through the Platform. Your information may be used in evaluating loan applications, facilitating loan approval and disbursement, managing repayment schedules, and conducting related operational processes connected with these services.
Compliance with legal and regulatory requirements
As a lending institution, we may be required to disclose, submit, or exchange certain customer information with competent regulatory authorities, other financial institutions, credit reporting agencies (such as relevant credit bureaus), and lenders (actual or prospective), including their authorized representatives, where required by law.
Loan recovery and collections
If repayment obligations are not met, we may share relevant information with collection agencies, legal advisers, or authorized representatives for the purpose of enforcing our rights as a creditor.
Business administration and operational support
We may engage third-party service providers who assist us in operating and managing our lending business. Personal information may be shared with such providers strictly for the purpose of supporting our internal operations and service delivery.
Customer feedback and service improvement
Your information may be used to request feedback regarding our services or to communicate with you about your experience with the Platform and the Products and Services we offer.
User communications
Where appropriate and with user consent, we may use information to facilitate communication between users through features available on the Platform.
Account management
Personal data may be used to create, maintain, and manage user accounts, ensuring the proper functioning and security of account-related services.
Administrative notifications
We may send service-related communications such as updates about products, new features, system notices, or changes to our Terms, conditions, and policies.
Platform security and fraud prevention
Information may be used to detect, monitor, and prevent fraudulent activities or other actions that could compromise the security or integrity of the Platform.
Enforcement of contractual terms and policies
Personal information may be processed when necessary to enforce our contractual rights, Terms of Service, or internal policies, as well as to meet legal or regulatory obligations.
Responding to legal processes and preventing harm
If we receive a lawful request from courts, regulators, or other authorities, we may review and process relevant information to determine the appropriate response.
Transaction management
Where applicable, we may use information to manage transactions conducted through the Platform, including payments and related financial processing activities.
Service delivery
Personal data may be used to provide and maintain the services you request through the Platform.
Customer support and inquiries
Information may be processed to respond to user questions, provide technical support, and resolve issues encountered while using our Platform or services.
Marketing and promotional communications
Subject to your communication preferences, we or our authorized marketing partners may use the information you provide to send marketing messages or promotional materials related to our services.
Personalized content and advertising
We may analyze certain information to present content or advertisements that may be more relevant to your interests or location, and to measure the effectiveness of such communications.
Operational analytics and product development
Information may also be used for broader business purposes, such as analyzing usage patterns, evaluating marketing campaigns, improving product design, enhancing service quality, and optimizing the overall user experience.
Profiling and automated decision-making
We may use automated systems and data analysis techniques, including profiling or credit scoring methods, when processing registration data, loan applications, and other interactions with the Platform. These processes may assist in evaluating eligibility for financial services or assessing credit risk.
4. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
4.1 Legal basis for sharing and processing
The Company acknowledges its obligations under applicable data protection laws and performs its responsibilities in accordance with this Policy. In order to deliver our Products and Services, you acknowledge and agree that certain data processing functions may be carried out by Growise and its authorized data processors. Such arrangements are governed by appropriate Data Outsourcing Agreements, which may be made available to you upon request.
We may process or disclose your personal information based on the following legal grounds:
Consent
Where you have explicitly granted permission, we may process your personal information for the particular purposes for which consent was provided.
Performance of a contract
When you enter into a contractual relationship with us, we may process your information as necessary to perform our obligations under our Terms of Service and any applicable Loan Agreement.
Compliance with legal obligations
We may disclose personal information when required to do so under applicable laws or regulations, including in response to lawful requests from government authorities, courts, or regulatory bodies, such as subpoenas, court orders, or similar legal processes.
Protection of vital interests
In certain circumstances, we may disclose information where necessary to investigate potential policy violations, detect or prevent fraud, address safety risks, or support legal proceedings in which we are involved.
5. WILL YOUR INFORMATION BE SOLD TO ANYONE?
5.1 Commitment to non-sale of personal information
We recognize the importance of protecting your privacy and treat the security of personal data as a core corporate responsibility. Without your clear and explicit authorization, we do not sell, trade, or otherwise commercialize your personal information to any third party. This restriction applies to all parties, including affiliated entities, suppliers, service providers, and business partners.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
6.1 Retention period
Your personal information will be retained only for as long as necessary to fulfill the purposes described in this Policy. If your account is terminated or closed, we will take reasonable steps to delete or remove your personal data, except where retention is required to meet legal or regulatory obligations, such as requirements relating to taxation, accounting, anti-money laundering compliance, or other statutory duties.
6.2 Deletion or anonymization
When there is no longer a legitimate business need to process your personal information, we will either permanently delete the information or convert it into an anonymized form so that it can no longer be associated with you. In situations where deletion is not immediately possible—for example, when the data is stored in backup systems—we will securely retain the information and prevent further processing until deletion can be completed.
6.3 User-initiated deletion
You may choose at any time to delete your account, uninstall the Platform from your device, or submit a formal request for the removal of your personal information, subject to the provisions of this Policy. Requests to delete personal data or withdraw consent for data processing may be submitted by contacting us through the appropriate channels.
6.4 Processing of deletion requests
We will make reasonable efforts to honor deletion requests within a reasonable period after receiving them, provided that doing so does not compromise the integrity, security, or proper operation of the Platform and related services, and is consistent with applicable legal and regulatory requirements.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
7.1 Security measures
We have implemented appropriate physical, technical, and organizational safeguards to protect personal information from unauthorized access, disclosure, alteration, or destruction. These measures are designed to comply with applicable legal requirements and generally accepted industry standards for data protection.
7.2 Staff responsibilities and training
All Growise personnel with access to personal information are required to handle such data in strict compliance with applicable laws and regulations. To support this, we maintain internal policies, conduct training programs, and provide guidance for stakeholders, directors, officers, employees, agents, and other relevant parties on privacy and data protection best practices.
Confidentiality obligations extend beyond the period of active engagement with Growise; former personnel remain bound to protect any personal information they encountered while associated with the company.
7.3 Privacy assessments and IT oversight
Growise regularly conducts Privacy Impact Assessments for projects, activities, and systems that involve personal data. Our IT team performs security policy reviews, vulnerability assessments, and penetration testing on a scheduled basis to maintain the integrity and safety of our systems.
Key considerations include:
a. Protecting Growise networks and systems from accidental, unlawful, or unauthorized use, interference, or breaches that could compromise data integrity or system availability.
b. Ensuring the confidentiality, integrity, availability, and resilience of our data processing infrastructure and services.
c. Monitoring for security breaches and identifying reasonably foreseeable vulnerabilities, while implementing preventive and corrective actions.
d. Maintaining the ability to restore access and availability of personal information promptly following a security incident.
e. Regularly testing and evaluating the effectiveness of security measures.
f. Applying encryption for personal data in transit and at rest, strong authentication procedures, and other technical controls to limit and manage access.
7.4 Limitation of security guarantees
Despite our protective measures, no electronic transmission over the Internet or storage system can be guaranteed fully secure. We cannot ensure that unauthorized parties will never overcome our safeguards, access, or misuse personal information. Transmission of personal data through the Platform is therefore at your own risk, and we recommend that you access the Platform only in secure environments.
8. DO WE COLLECT INFORMATION FROM MINORS?
8.1 Age restrictions and parental consent
We do not knowingly collect personal information from, or target services to, individuals under 18 years of age. By using the Platform, you confirm that you are at least 18 years old, or that you are the parent or legal guardian of a minor using the Platform, and consent to such use by the minor.
If we discover that we have inadvertently collected data from a person under 18, we will deactivate the account and take reasonable steps to delete the information promptly. If you become aware of personal data of minors under 18 collected through the Platform, please notify us at help@growisefortglo.com.
9. WHAT ARE YOUR PRIVACY RIGHTS?
9.1 Your rights under applicable law
Under relevant data protection laws, you have the following rights regarding your personal information:
a. The right to be informed about whether your personal information is collected, processed, or stored.
b. The right to object to the processing of your personal information.
c. The right to access your personal information in a reasonable manner.
d. The right to request correction of any inaccuracies or errors in your personal information.
e. The right to request the suspension, withdrawal, blocking, removal, or destruction of your personal information from our records.
f. The right to lodge a complaint with the relevant government authorities for violations of your data privacy rights.
g. The right to seek compensation for damages caused by inaccurate, incomplete, outdated, unlawfully obtained, or unauthorized use of your personal information.
h. The right to data portability of your personal information.
i. The right to know if your personal information is subject to automated processing, automated decision-making, or profiling.
j. The right to inquire whether your information has been sold or shared with third parties.
9.2 Exercising your privacy rights
You may exercise your privacy rights by contacting us to:
a. Opt out of sharing your information with our affiliates, subsidiaries, or business partners, provided that this does not interfere with the services you have received and is not required by applicable law.
b. Request the personal information we hold about you, subject to legal or regulatory restrictions in the jurisdictions where Growise operates.
c. Update or correct your personal information.
d. Raise any concerns related to how we collect, use, store, share, or dispose of your information.
e. Request suspension or cessation of sharing or selling your information to third parties.
9.3 Account closure
If you request to terminate your account, we will deactivate or remove your account and associated information from our active systems. Certain information may be retained in accordance with legal obligations, fraud prevention, troubleshooting, investigations, or to enforce our Terms and Services.
10. ACKNOWLEDGMENT AND CONSENT
10.1 Acceptance of this Policy
By using the Platform and our Products and Services, you acknowledge that you have read, understood, and agreed to the terms of this Privacy Policy, including the collection, processing, and transfer of your personal information as described herein.
10.2 Consent to automated processing
You agree that Growise may process your personal data through automated systems, including automated decision-making, profiling, and other analysis, in connection with your account application, management, maintenance, closure, and use of our Platform and Products and Services.
11. UPDATES TO THIS POLICY
We may revise this Privacy Policy periodically. Material changes will be communicated by either updating this notice on the Platform or by sending you a direct notification. We encourage you to review this Policy regularly to stay informed about how we protect your personal information.
12. CONTACTING US AND EXERCISING YOUR RIGHTS
12.1 General inquiries
For questions or comments regarding this Policy, you may contact us by email at help@growisefortglo.com.
12.2 Requests regarding your personal information
You have the right to request access to the personal information we hold, request corrections, request deletion, or request cessation of sharing. To exercise these rights, email help@growisefortglo.com.