DISCLOSURE STATEMENT AND PRIVACY POLICY

ISHTIRAK MICROFINANCE (PRIVATE) LIMITED

The “Ishtirak” online digital lending is owned and operated by Ishtirak Microfinance (Private) Limited, a company incorporated under the provisions of the Companies Act, 2017, holding CUIN 0285256 (hereinafter referred to as “Ishtirak Microfinance (Private) Limited” having its registered office at 96-A Block G, Gulberg III, Lahore. Ishtirak Microfinance (Private) Limited is engaged in the business of providing micro and nano-loans to its customers in Pakistan through the “Ishtirak” (hereinafter referred to as the “Ishtirak”).

Ishtirak Microfinance (Private) Limited is committed to protecting and respecting your privacy. This Privacy Policy is designed to help you to understand how Ishtirak Microfinance (Private) Limited will collect, store, and process your data when you login to Ishtirak and use Ishtirak's services.

All users or customers of Ishtirak are strongly advised to read and understand this Privacy Policy carefully, as by accessing Ishtirak you agree to be bound by the terms of this Privacy Policy and consent to the collection, use, disclosure, safe storage and protection of your personal information by Ishtirak Microfinance (Private) Limited in accordance with this Privacy Policy, or any changes made hereto.

Ishtirak Microfinance (Private) Limited may update or revise this Privacy Policy from time to time. Any updates or revisions will be communicated to you in advance through a notice on Ishtirak’s homepage and/or via email to the address registered with your account. In the event of material changes, the details of the changes will also be communicated via the homepage and/or email, and your explicit consent will be obtained before the revised policy takes effect. If you do not agree with the updated policy, you will be provided with a clear option to stop using our services. We encourage all users to periodically review this Privacy Policy to stay informed about how we protect and manage your information.

For the purposes of this Privacy Policy, the terms “you” or “customer” shall include any visitor, user, business partner, agent, supplier, vendor, or customer of Ishtirak Microfinance (Private) Limited, collectively referred to as a “User.” The terms “we” or “us” refer to Ishtirak Microfinance (Private) Limited.

1 When this Privacy Policy applies

1.1 This Privacy Policy shall apply to all instances in which you access, register for, provide information to, upload or submit documents via, or otherwise engage with or subscribe to Ishtirak’s products, services, applications, websites, or networks. Such engagement includes, without limitation, services and applications related to data, video, advertising, internet, and other offerings including but not limited to other products, services and applications, all of which are subject to the terms of this Policy.

1.2 This Privacy Policy also applies to you and anyone who uses our products or services under your account, except where we identify that a separate privacy policy or terms and conditions apply. You are responsible to ensure that you understand this Privacy Policy.

1.3 You must agree to and be willing to accept the terms of this Privacy Policy before you can access or use Ishtirak, or any of the products or services offered therein.

1.4 This Privacy Policy and any additional terms of use apply to you even if you are not our customer and you interact with us as part of running our business, such as by:

1.5 If you need to give us personal information about someone else in relation to our products and services, this Privacy Policy will also apply.

1.6 Depending on the product or services, you may also receive service-specific and/or region-specific terms. You will be legally bound by both this Privacy Policy and the service/region specific term to the extent that you have accepted them when signing up to any service or product; therefore, you are required to read these terms carefully.

1.7 It is your responsibility to ensure that all personal data submitted to Ishtirak Microfinance (Private) Limited are accurate. You are also responsible for maintaining the accuracy, correctness and completeness of personal data and for keeping the data up-to-date.

2. What Information We Collect

2.1 Ishtirak Microfinance (Private) Limited is committed to protecting all Personal Information (defined below at clause 2.2) of its employees, customers, business partners, suppliers, contractors and other parties that Ishtirak Microfinance (Private) Limited will engage with.

2.2 To this end, Ishtirak Microfinance (Private) Limited hereby formulates uniform practices and procedures for the collection, recording, consolidation, update, disclosure, storage, access, transfer, retention, destruction and for the fair, proper and legal processing of your Personal Information. The terms of this Privacy Policy apply to all persons whose Personal Information is processed by Ishtirak Microfinance (Private) Limited through Ishtirak.

“Personal Information” means any information that can be used by itself to uniquely identify, contact, or locate a person, or can be used with information available from other sources to uniquely identify an individual, such as personal information that you provide when you make any request, use our services, set up a user account or otherwise interact with us or provide information, which includes your name, father's name, mother's name, CNIC, passport number or any other personal identification number, mailing/home address, e-mail address, phone/mobile number, home country, occupation, educational background, and zip/postal code, SIM card, age, gender, username, password and other registration information (such as the security questions and answers we have on your account), personal description and photograph.

2.3 Only after obtaining your additional explicit consent, we may collect some other personal information about you. For example, One-Time-Password (OTP) auto-fetching, or SMS alerts sent by Ishtirak Microfinance (Private) Limited, your reference contacts in the loan application may be collected for risk control purposes; your location information (IP address, longitude and latitude information) may be collected for anti-fraud purposes. Ishtirak Microfinance (Private) Limited may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this Privacy Policy for as long as it is combined.

2.4 When you use Ishtirak, we collect and store your Personal Information based on your express consent to this Privacy Policy. Once collected, this information is clearly displayed on Ishtirak and is accessible only to you. The collection of this data enables us to offer services and features tailored to your needs, enhancing your experience and making your interactions with Ishtirak more efficient and user-friendly. Importantly, we only collect the Personal Information that we believe is necessary to fulfill the purposes outlined in this Privacy Policy. Generally, you are not required to provide any Personal Information while browsing Ishtirak. However, when creating an account on Ishtirak you must provide us with certain basic information required to provide customized services.

2.5 We collect information when you register with us via the Ishtirak by creating an account or when you respond to advertisements or posts on Ishtirak, including information and data provided by you when filling in the forms as part of any advertisement or post, or on Ishtirak, and information and data provided in the course of any correspondence with us (for example, by e-mail or chat or helpline).

2.6 We collect and upload a list of account information recorded by the user account management center on your device, such as your Gmail/Facebook/email account name and account type. We will save this account information in our system database for creation of your user account. We will use this information in order to monitor your use of Ishtirak for AML and CFT purposes, as and when deemed necessary by Ishtirak Microfinance (Private) Limited.

2.7 We collect information and data you provide when you register to use any products or services via Ishtirak, download or register the same, subscribe to any of our services (such as applying for a loan), search for a product, service or application, share data via Ishtirak, enter a competition, promotion or survey, and when you report a problem with Ishtirak or our services, through a mode of communication available on Ishtirak.

2.8 Ishtirak Microfinance (Private) Limited and its authorized third-parties may also collect, store and process personal information such as password, financial information (details of bank account, credit card, debit card, or other payment instrument details) and other relevant information in order to enable us to more effectively market and provide our products, services and for use of our Ishtirak.

2.9 We may also collect your information from outside sources such as credit reports, marketing mailing lists, and commercially available geographic and demographic data/information.

2.10 We may collect information when you install or uninstall Ishtirak to avail any products or services. Such product or service may contain a unique application number or when such a product or service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

2.11 If you, another user or any third party sends us a private letter or email or other communication about your activities or posts on Ishtirak, we will collect and retain this information in a file specific to you.

2.12 Reference Contacts: Subject to your prior express consent, we shall collect information of your reference contacts when you enter the details of the reference contacts on Ishtirak, in order to verify details provided by you during the loan application process. Risk analysis requires this information to allow us to test reliable references to prevent fraud and track collections.

2.13 Each time you visit Ishtirak, we may, in addition to the above, collect the following information:

2.14 We collect information about your device to provide automatic updates and add-ons. In addition, this information provides us with valuable feedback about your identity as the device owner and your device behavior, thereby allowing us to improve our services and provide you with an enhanced customized user experience.

2.15 The information collected by Ishtirak and how it is used depends on how you configure the privacy settings on your device. When you install Ishtirak, we will store the information we collect through a unique identifier bound to the device you use.

2.16 You agree that Ishtirak Microfinance (Private) Limited may collect, store and process all of the information mentioned above which we may collect as part of your interaction with Ishtirak Microfinance (Private) Limited, including third-party supplied information. By using Ishtirak, customers hereby agree and consent to the collection, and use of the personal information for any of the products or services that we offer, and consent to our collection of any changes or updates to such information.

3. What we use the information for

3.1 Information collected by us (or where applicable and necessary, the parties stated at clause 3.3) shall be used exclusively in connection with providing you with financial services via Ishtirak. In this regard:

  1. i. Personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested;
  2. ii. Improve our /app in order to better serve you;
  3. iii. Allow us to better service you in responding to your customer service requests;
  4. iv. Administer a contest, promotion, survey or other site feature;
  5. v. Ask for ratings and reviews of services or products; and
  6. vi. Follow up with them after correspondence (live chat, email, phone inquiries, or WhatsApp), either directly with the user or with and through an authorized person of reference whose information has been provided by the user to Ishtirak Microfinance (Private) Limited. The said modes of communication will be conducted exclusively through official channels, and all such communications shall be duly recorded.

3.2 This means we may:

3.3 In addition, we use the following information to provide products and services and manage your account:

4. When we may disclose information to third parties

4.1 We may disclose some or all of the data we collect from you when you download or use Ishtirak to connect to mobile wallet providers, credit bureaus, duly licensed lenders or other partner financial institutions. We may, with your consent, disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, and any agents or counsels of Ishtirak.

4.2 We may also use a third-party payments services provider or payments processing company to process payments and repayments, transfer money to your operative user account, process other payments, and to provide additional products and services, and may therefore disclose your information to such third-party payments’ services provider.

4.3 We may disclose your personal information to any local or international law enforcement officers or competent regulatory or governmental agencies or a court of competent jurisdiction, in good faith belief that such disclosure is reasonably necessary to enforce any terms and conditions and/or this Privacy Policy, to assist in the prevention, detection, investigation or prosecution of criminal activities or fraud, to the extent allowed by applicable laws of the country.

4.4 We shall use your data for the purposes of compiling statistic relating to our user base or financial product or services and may disclose such information to any third party for such purposes, provided that such information will always be anonymous.

4.5 We may use other third-party companies to monitor site traffic, which may, in some instances, store customer information. Where we use another organization, we still control your personal information and we have strict controls in place to make sure it's properly protected.

4.6 We may also disclose or transfer your personal information to third parties in the event that:

4.7 We may also disclose such information in order to enforce any Ishtirak terms and other agreements or to investigate potential breaches; report defaulters to any credit bureau or for the purpose of publishing statistics relating to the use of Ishtirak, in which case all information will be aggregated and made anonymous.

4.8 We may use your Personal Information or any other information obtained as stated in this Privacy Policy in order to contact you via telephone, email, Whatsapp/messenger, SMS or any other means of communication as may be available and appropriate.

5. Tracking and Cookies

5.1 "Cookies" are small text files transmitted by a web server to the hard drive or storage of a user’s device and stored therein. Such files may collect and store information including, but not limited to, the date and time of website visits, browsing patterns, user preferences, and login credentials (such as usernames), for the purposes of enhancing user experience and enabling certain website functionalities.

5.2 Ishtirak may use Cookies to manage our users' sessions and to store preferences, tracking information, and language selection. Cookies may be used whether customers register with us or not.

5.3 In some instances, our third-party service providers may use cookies on Ishtirak. We cannot control or access cookies used by third-party service providers. This Privacy Policy covers only Cookies used by us, and not any Cookies used by third parties.

5.4 Customers may have the ability to either accept or decline the use of Cookies on your computer, whether registered with us or not. Typically, you can configure your browser to not accept Cookies. However, declining the use of Cookies may limit your access to certain features of Ishtirak. Cookies helps us to provide you with a good experience when you use Ishtirak and also allows us to improve Ishtirak.

5.5 We will not use Cookies for any purposes not stated in this Privacy Policy. You can clear all the Cookies stored on your computer, and most web browsers provide the option of blocking Cookies. However, by doing so, you have to change the user settings every time you visit our website.

5.6 In addition to Cookies, we may also use other similar technologies on our Ishtirak such as web beacons and pixel tags. For example, when you receive an email from us, it may contain a click-through URL that links to our web page. If you click the link, we will track your visit to help us learn about your preferences for products and services and improve our customer service. A web beacon is a transparent graphic image embedded in a website or application or in an email. We use pixel tags in emails to find out whether an email has been opened. You can unsubscribe from the mailing list at any time if you do not want to be tracked in this manner. By using our Ishtirak and consenting to this Privacy Policy, you consent to the use of Cookies, web beacons and pixel tags as described above.

5.7 We retain above information to resolve necessary disputes, provide support to users, and resolve issues permitted by law.

6. Changes to User Information

You can choose to edit/modify or delete/withdraw any your own personal information submitted on or for use of Ishtirak at any time. Please note that deleting or withdrawing information may affect the services we provide to you. If there is any change in personal information made by you, you must provide supporting documents related to the change of personal information for verification by Ishtirak.

7. Security Practices and Safety Precautions

7.1 We adopt reasonable security practices and procedures, to include, technical, operational, managerial and physical security controls in order to protect your personal information from unauthorized access, or disclosure while it is under our control. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential.

7.2 The data and information we collect from you may be transferred to, and stored at, a destination, i.e. it is encrypted and stored on the Ishtirak server. The staff members at the destination may be engaged in the fulfillment of your requests. By submitting your personal information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

7.3 Our security practices and procedures limit access to personal information on need-only basis. Further, our employees are bound by code of conduct and confidentiality policies which obligate them to protect the confidentiality of personal information.

7.4 We maintain the security of our Ishtirak, however, for reasons beyond of our control, security risks may still arise. Any personal information transmitted to us or from our online products or services will therefore be your own risk. However, we will use all reasonable efforts to ensure the security of your information. We observe reasonable security measures to protect your personal information against hacking and virus dissemination.

7.5 Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Ishtirak, you are responsible for keeping this password confidential. We maintain the security of our Ishtirak, however, for reasons outside of our control, security risks may still arise. Any personal information transmitted to us or from our online products or services will therefore be your own risk. However, we will use all reasonable efforts to ensure the security of your information. We observe reasonable security measures to protect your personal information against hacking and virus dissemination or prevention of unauthorized access, to the extent reasonably practical.

7.6 You agree that Ishtirak or any of its affiliates, associated or related entities, employees, directors, shareholders, agents, counsels or representatives etc. shall have no liability towards you in case of any unintended security breach which results in unauthorized access to, or disclosure of, your information. You agree to waive, to the fullest extent permitted by law, all of your rights to seek damages or otherwise hold Ishtirak and its related entities liable for any security breach resulting in disclosure or unauthorized access to your information.

8. Privacy Control and Permissions

8.1 Regarding the information we collect and how it is collected, you have specific choices that may control what information we collect after using your device. For example, you can modify the permissions on your Android or iOS device to access camera or audio permissions or delete your account on Ishtirak. You can also delete content from our servers, subject to applicable laws, by requesting us via email at info@Ishtirakpay.com.

8.2 Once you have deleted your account, you will no longer be able to use the services via Ishtirak. Ishtirak reserves the right to retain your personal information in accordance with relative applicable laws and regulations for a retention period required by the laws. Upon the expiration of the retention period, we will remove or anonymize your personal information.

8.3 To the extent required by applicable law, you may

To exercise these rights, please write to our data protection officer on:
Data Protection/Privacy Officer
Ishtirak Microfinance (Private) Limited
Email: info@Ishtirakpay.com

8.4 For security purposes, we may require a written request from you. Please note that, when you object to, or restrict our use of your personal data, this may affect our ability to provide certain products or services to you. We reserve the right to decline any such request if we have reasonable grounds to believe that it is fraudulent, impracticable, or may jeopardize the privacy or rights of others.

9. Link to other websites or applications

9.1 Ishtirak contains links to other websites or applications that are neither owned nor operated by Ishtirak. Such websites or applications may collect your personally identifiable information independently. We are not responsible for the privacy practices or content of these linked websites or applications and only deal with the disclosure and use of the information we collect through Ishtirak as stated in this Privacy Policy. Kindly ensure to review privacy policies of websites or applications that you visit which have been linked on the Ishtirak to ensure safety of your personally identifiable information.

10. Your Consent to the Collection, Use and Disclosure of Information

10.1 By using Ishtirak and/or by providing your information, you agree to the collection, use and processing of the information you disclose or that generated as a result of your use of our service on the or Ishtirak in accordance with this Privacy Policy, including but not limited to your consent to the collection, use, sharing and disclosure in accordance with this Privacy Policy your message. If we decide to change our Privacy Policy, we will post these changes on Ishtirak so that you can always know what information we collect, how we use it, and under what circumstances we disclose it.

10.2 By providing us with your contact information, including your home or mobile phone number, we obtain your permission to contact you or the authorized person whose details have been provided by you to Ishtirak through SMS, manual or pre-recorded voice messages and automatic dialing technology, WhatsApp, email, live-chat, and post, for all purposes that are not prohibited by applicable laws. Standard message and data rates may apply. Such communications may relate to, but are not limited to; suspected fraud or identity theft; obtaining information; transactions or services of your account; collecting your account or collecting accounts that are in arrears. The rights granted to us under this section are also extended to our company's affiliates, subsidiaries, agents, suppliers, ultimate holding company or its subsidiaries.

11. Exercise Access, Rectification, Cancellation and Opposition (“ARCO”) Rights

11.1 To the extent required by applicable laws, you have the right to access your personal information collected by us and to obtain details regarding their processing. You also have the right to rectify them if they are inaccurate or cancel their use through a written request addressed to the following email address info@Ishtirakpay.com or by submitting a letter within the office facilities of Ishtirak during office hours on working days, said requirements will be addressed on priority basis. Please note that deletion or withdrawal of certain information may affect the services we provide to you. If there is any change in personal information made by you, you must provide supporting documents related to the change of personal information for verification by Ishtirak.

11.2 To exercise ARCO rights, an application must contain and accompany the following information and documentation:

11.3 Ishtirak will not be obliged to delete any personal information when

11.4 You may also at any time oppose the processing of your data that is not essential for the legal and/or commercial relationship established with Ishtirak by you, which you may do through the procedure indicated here.

11.5 In the processing of your personal information, it is primarily anticipated that its protection is against any damage, loss, alteration, destruction, and against any unauthorized use, access or processing.

11.6 Subject to applicable laws, you have the right to withdraw your consent to the collection, storage, processing and disclosure of your information at any time, provided that you have no outstanding obligation towards Ishtirak. Upon withdrawal of your consent, you will no longer be eligible to use Ishtirak or maintain a user account with Ishtirak. You can also withdraw your consent for further collection of this information at any time by logging out and uninstalling the Ishtirak mobile or other applications from your device.

12.

Subject to applicable laws, you have the right to withdraw your consent to the collection, storage, processing, and disclosure of your information at any time, provided that you have no outstanding obligations towards Ishtirak. Upon withdrawal of your consent, you will no longer be eligible to use Ishtirak’s services or maintain a user account. You may also withdraw your consent for further collection of information by logging out and uninstalling the Ishtirak mobile or other applications from your device.

12.1 We process your personal data based on your consent. However, withdrawal does not affect the legitimacy and effectiveness of how we process your personal data based on your consent before the withdrawal is made; nor does it affect any data processing based on another justification other than your consent.

13. Protection of Minors

13.1 We place great value on the protection of minors' personal information. As required by applicable laws and regulations, any user under the age of 18 should be banned to use our service. As the parent or statutory guardian of a minor, it is your responsibility to prohibit your child from using our service. Otherwise, all legal consequences are borne by yourself.

14. Disputes

14.1 With respect to any disputes regarding this Privacy Policy including but not limited to any provisions related to indemnification, limitation of liability relating to damages, choice of law and dispute resolution forum, we ask you to first submit any such complaints directly to us the relevant customer services desk or helpline.

15. Contact Us

You may contact us with any questions, comments, requests, or feedback regarding this Privacy Policy through the website: www.Ishtirakpay.com.pk or via e-mail: info@Ishtirakpay.com Our contact information is as follows:

Company name: Ishtirak Microfinance (Private) Limited
Trade name: Ishtirak
Contact Number: 0423-5866466
Contact us by email: info@Ishtirakpay.com
Service timing: 09:00 - 17:00 hours - Monday to Friday