Pak Paisa Installment Plan Privacy Policy

Introduction

Pak Paisa (“we,” “us,” or “our”) is committed to safeguarding your personal information. This Privacy Policy explains how we collect, process, and protect your personal data when you access our website (pakpaisa.com.pk) and mobile applications (collectively, the “Platform”) for purchasing products on installments. It also informs you of your rights and how the law protects your privacy.

Your Rights

Under applicable data protection laws, you have the following rights regarding your personal information:

1. Right to Object to Direct Marketing:
   You may request that we stop processing your data for marketing purposes. We will promptly discontinue these activities.

2. Right to Object to Legitimate Interests:
   You may object to the processing of your data when it is based on our legitimate interests. We will assess your objection and comply if appropriate under the law.

Your Responsibilities

By using our Platform for installment purchases, you acknowledge that you have read, understood, and agreed to this Privacy Policy and consent to our data collection and processing practices.

Personal Information and How We Use It

Definition

Personal information refers to data that identifies you as an individual. This policy does not cover anonymized data where identity cannot be determined.

Categories of Personal Information Collected

We may collect the following types of personal information:

1. Identification Information: Name, title, date of birth.

2. Contact Information: Postal address, email, phone number.

3. Professional Information: Employment details, organization.

4. Financial Information:

   • Salary, savings, and financial history

   • Creditworthiness and payment history

   • Payment methods and bank account details for installments

5. Communications: Queries, feedback, and correspondence with Pak Paisa.

6. Updates: Amendments to previously provided information.

7. Third-Party Sources: Information from authorized third parties.

This information is collected to enable your use of the Platform, assess installment eligibility, process purchases, and comply with legal requirements.

Information Automatically Collected

When you use the Platform, the following may be automatically collected:

1. Technical Information:

   • IP address, browser type/version, operating system, device type

   • Referring website, country of access, files requested

2. Behavioral Information:

   • Pages visited, clicks, scrolls, session duration

   • Navigation patterns and interaction with features

   • Data submitted when using services or downloading content

Purpose: Improve user experience, optimize content, analyze traffic, ensure security, and enhance service delivery.

Collection from Installed Applications

We may collect metadata from applications installed on your device to:

• Assess eligibility for installment offers

• Personalize and pre-approve suitable product plans

Information may include application name, version, installation/update time, and package name.

Camera and Microphone Access

We may require:

• Camera Access: To scan IDs, capture images for verification, and auto-fill application fields.

• Microphone Access: To facilitate two-way communication with agents for verification or customer support.

CNIC and Facial Photo Collection

Data collected via CNIC scans and facial recognition is solely for identity verification and KYC purposes and will be retained per legal requirements.

Data Security and Retention

• Personal data is stored securely and managed according to regulatory requirements.

• Aggregated data may be anonymized for analytics and reporting.

• Special categories of data, such as race, religion, or health, are not collected.

Use of Personal Information

We may use your data to:

1. Respond to inquiries and support requests.

2. Administer installment plans, process payments, and manage your account.

3. Comply with legal and regulatory obligations.

4. Conduct internal administration, research, and analytics.

5. Detect and prevent fraud, money laundering, or other unlawful activities.

How We Collect Information

1. Directly from You:

   • Account creation and product applications

   • Online forms, requests, or feedback

   • Participation in surveys, promotions, or competitions

2. From Third Parties:

   • Credit bureaus, banks, and payment processors

   • Public sources or referral partners

Sharing Your Personal Information

Internal Use:

With group companies for administrative purposes like compliance, auditing, and quality assurance.

Third-Party Disclosure:

Your data may be shared with:

• Service providers (payment processors, identity verification agents, logistics partners)

• Credit bureaus for creditworthiness assessment

• Strategic partners for product offers or promotions

• Regulatory authorities as required by law

• Lenders or investors during corporate transactions

All third parties are required to process your data securely and lawfully.

Special Cases:

• Business transfers or acquisitions

• Court orders, legal obligations, or fraud investigations

No unauthorized sharing: We will not sell or rent your personal information without consent.

Marketing Communications

• We may use your information to send promotions via SMS, WhatsApp, email, phone, or postal mail.

• Communications may be based on:

  • Legitimate interests for existing customers

  • Explicit consent where required

• You can opt-out at any time using provided mechanisms or by contacting us.

Credit Bureaus and Fraud Prevention

• Your credit history may be checked to evaluate eligibility for installment plans.

• Data from Credit Information Bureaus may include public records, credit reports, and fraud prevention information.

• Defaulted payments may be reported to CIBs, impacting future credit assessments.

Your Legal Rights

You may exercise the following rights:

1. Access your personal information.

2. Update or correct inaccurate data.

3. Request deletion where lawful.

4. Object to processing based on legitimate interests.

5. Withdraw consent for marketing communications.

6. Restrict processing in certain scenarios.

7. Request data portability in machine-readable format.

Requests can be made by contacting us; we may verify your identity before processing requests.

Data Security and Retention

• Data is stored securely and protected from unauthorized access.

• Retention depends on operational, legal, and regulatory requirements.

• Anonymized data may be retained for research or statistical purposes.

Links to Other Websites

Our policy does not cover external websites. Please review their privacy policies when visiting links from our Platform.

Changes to this Privacy Policy

We may update this policy periodically. Updates will be reflected on our Platform and, where appropriate, communicated via email.

Controller Contact Details

Pak Paisa is the controller responsible for your data. Contact details are available on our Platform’s Contact Us page.

Complaints

You have the right to lodge a complaint with the National Commission for Personal Data Protection of Pakistan (NCPDP). We encourage you to contact us first to resolve your concerns.

Effective as of: December 2024