Privacy Policy

Privacy Policy QarzMitra is an online financial application (QarzMitra App) developed by FINTECH GHARANA FINANCIAL (PRIVATE) LIMITED (Company), a non-banking financial company (NBFC) providing lending and investment services in Pakistan. The company operates under license number No.SECP/LRD/131/FGFPL/2025, granted by the Securities and Exchange Commission of Pakistan (SECP). The QarzMitra App is committed to offering financial lending services in a transparent and secure manner, ensuring compliance with local regulations. This privacy policy outlines how QarzMitra App collects, stores, and protects user data when visiting or using it or Company’s website. This privacy policy has been formulated to address concerns and requirements regarding the collection and use of personal information of borrowers. This privacy policy outlines how QarzMitra App collects and processes personal information of a borrower across devices, products, services, and online platforms. Please note that, subject to the express and explicit consent of the borrower while using the App, QarzMitra App will only collect the following information. Kindly read the details carefully. 1. Information QarzMitra App Collect: In compliance with SECP Circulars No. 12 of 2024 and 14 of 2024, QarzMitra App collects borrowers’ data solely with explicit consent and for legitimate purposes related to digital lending services. All data collection and its use are subject to the explicit consent of the user in accordance with Clauses 1(e), 5( c)(ii), 7(a) and Annexure-C Clause C(i) of Circular No. 12 of 2024. QarzMitra App may collect the following data types; • Personal Identification Data • Biometric Verification • Banking Information • KYC Data • Device Information • Loan and Transaction Data The collected date is used for the following Purposes; • Creditworthiness evaluation • Loan processing and repayment monitoring • Mandatory regulatory reporting • Legal compliance and fraud prevention • Communication related to product servicing a) Personal Identity Information Personal Identity Information is collected for identity verification and fraud prevention and it includes name, CNIC number, contact number, address, and work information. Data is handled per Clause 1(e) and 7 of Circular No. 12 of 2024. To ensure the authenticity and reliability of the information collected, QarzMitra needs to conduct necessary verification and confirmation of key data such as borrower’s name, ID number, telephone number, residential address, work information, etc. This key information is also used to protect borrowers’ rights and security and prevent identity fraud and abuse. QarzMitra App strictly abide by relevant laws and privacy policies to protect and manage borrowers’ personal information and ensure its security and confidentiality. QarzMitra App undertakes to use this key information only when necessary and will not disclose it to any unauthorized third party. QarzMitra App will take reasonable technical and management measures to prevent data leakage, abuse and damage of borrowers’ personal information. b) Device Information Includes device type, operating system version, and installed apps. This Data helps in optimizing app performance and verifying creditworthiness, in compliance with Clause 1(a), 1(e), and 6(d) of Circular No. 12 of 2024. Details such as device type, operating system, and browser type are collected to enhance user experience and ensure security. To better serve the borrower, QarzMitra collects hardware and software information such as browser type, device type, operating system, software version, hardware model, mobile network information, and domain names used when accessing services. This information is used to optimize and improve our services. Protecting borrowers’ privacy and data security remains our top priority, and QarzMitra will take necessary security measures to protect borrowers’ personal information. QarzMitra App also undertake to use this information only with borrower’s consent and not for any other purpose. c) List of Installed Applications A list of installed applications may be collected to assess creditworthiness. To ensure the security and compliance of the application, QarzMitra will collect a list of applications installed on borrower’s device, including application name, package name, installation time, etc. The obtained application list will be filtered by keywords, encrypted and uploaded to QarzMitra Loans secure center (https://arzs.qarzqarzsafety.com/) for encryption. d) Financial Information Financial Information: Income, expenses, debts, and assets information are gathered to evaluate credit risk accurately. To assess borrowers’ financial worthiness and to determine the borrower’s credit scores, QarzMitra may collect data about income, expenses, debts, assets, and other financial liabilities of financial institutions, including banks and other lending entities. This information helps us accurately evaluate users' creditworthiness and risks to ensure the safe and reliable disbursement of loans. e) Location Information With explicit consent, the approximate geographic location is collected to verify residential and work addresses. Subject to the express and explicit consent of the borrower, QarzMitra App will collect the borrower’s rough geographic location/s data while using the App, to verify if it matches the borrower’s work and residential address. Borrower’s location date will enable QarzMitra App to provide better location-based services and personalized experiences. f) Camera Permission and Image Information The camera is used only to capture a live selfie or perform biometric verification for KYC, as per Clause 6(d) of Circular No. 12 and Clause 17 of Annexure-A of Circular No. 14. Subject to the express and explicit permission of the borrower, to address the prospective risk of identity theft; QarzMitra App shall require access to borrower’s device camera to get a live selfie photo for verification or In-App biometric verification as part of KYC process. QarzMitra App is committed to protecting borrowers’ privacy and photo security and will never misuse borrower’s personal information. When the borrower uses features that require uploading images, such as the customer service chat feature, QarzMitra App will obtain all selected image data and upload and transmit it securely to the server (https://arzs.qarzqarzsafety.com/). Please note that QarzMitra App cannot access or retrieve borrower’s photo albums from the borrower’s device through this method. QarzMitra App will never disclose this information without permission and only collect this information with the borrower’s explicit consent. g) Social Account Information and GAID It is used for analytics and ad personalization. Data is encrypted and shared only with analytics providers under strict confidentiality agreements (e.g., Firebase, AppsFlyer), in line with Clause 3(c) of Circular No. 12. QarzMitra collects information related to users' social accounts to improve communication. This data will be encrypted and uploaded to the QarzMitra Loans secure center(https://arzs.qarzqarzsafety.com/). Apps Flyer are Used to optimize advertising performance and conduct data analysis. QarzMitra will collect and share device-related information for advertising performance analysis, data statistics optimization, and push personalized marketing activities to the borrower, to ensure that the borrowers are informed of push notifications and order status in a timely manner. QarzMitra collect Google Advertising ID (GAID) to provide more precise advertising services. GAID is a non-permanent device identifier used for ad delivery and tracking in mobile applications. By collecting the GAID, QarzMitra can better understand users' ad preferences and behavior, allowing us to display advertisements more aligned with their interests and any advertisement and publication shall contain full disclosure regarding loans on offer and applicable APR. h) Collaborator The software development kit (SDK) QarzMitra utilizes to connect with Deeplink third-party services is distributed across various social networks, including Google and Facebook. It discerns the attribution source of user channels and communicates the identity of each channel. Neither Deeplink nor QarzMitra App accesses or uses any information from users' private accounts. 2. Use of Information Subject to clause 7 of Circular 12 of 2024, All collected data is processed in accordance with SECP regulations to: • Assess creditworthiness and manage risk. • Prevent fraud and unauthorized access. • Enhance user experience and service delivery. Data is encrypted and stored securely, ensuring confidentiality and integrity, as mandated by Clause 8( a) of Circular No. 12. • Personalized Services: QarzMitra use borrower's personal information to create and maintain accounts, providing customized services and features, such as recommending specific content, products, or activities based on borrower’s preferences. • Notifications: QarzMitra App may use the borrower’s contact information to send app updates, promotions, and notifications. The borrower can opt out of receiving these at any time. • App Optimization: QarzMitra App uses non-personal information to analyze user behavior and preferences to improve app performance and user experience. This helps us identify popular features and areas for improvement. QarzMitra App uses collected data to: • Provide personalized services and content. • Send notifications and updates (opt-out available). • Improve app features and optimize user experience. This processing is in line with Clause 1(e) and Clause 7 of Circular No. 12. 3. Disclosure of Information to Third Parties • When a borrower downloads or uses the QarzMitra Platform, QarzMitra App may disclose certain personal data to third parties as necessary to connect the borrower with mobile wallet providers, credit bureaus, or our partner financial institutions. QarzMitra may also share borrowers’ personal information with members of our corporate group, including our parent company, subsidiaries, and affiliated entities. • To facilitate transactions such as loan disbursements, repayments, or other related financial services, QarzMitra App may use third-party payment service providers. In such cases, the borrower’s relevant data may be shared with those service providers for the purpose of executing financial operations. • QarzMitra App may disclose borrowers’ information to local or international law enforcement agencies, regulatory bodies, or government authorities in good faith where such disclosure is reasonably necessary to enforce our Terms and Conditions or this Privacy Policy, or to detect, prevent, or investigate illegal activities or fraud. • Borrower’s data may be used for compiling statistics related to platform usage or financial service performance. Any such data shared with third parties will be anonymized and aggregated, ensuring that no individual user can be identified. • QarzMitra App may engage third-party analytics providers to monitor traffic and user activity on the QarzMitra Platform. While such providers may store customer data, QarzMitra App maintains full control over the borrower’s information and enforces strict data protection and confidentiality measures. • QarzMitra App may also disclose or transfer borrowers’ data under the following circumstances: a) In the event of a merger, acquisition, bankruptcy, reorganization, liquidation, or sale of QarzMitra App assets, QarzMitra App may share borrowers’ data with the relevant parties related to such event; b) If QarzMitra App or substantially all of its assets are acquired by a third party, the borrower’s personal data may be part of the transferred assets; c) Where QarzMitra App is required to do so due to the operation of applicable law or regulatory obligations/enforcement. • To enforce terms or investigate potential breaches, or to report defaulters to credit bureaus, QarzMitra App may use or disclose anonymized and aggregated data for statistical and reporting purposes. • QarzMitra App may also contact the borrower by using the personal information collected (including the borrower’s phone number) via SMS or other messaging channels for service-related updates or communications, in accordance with this Privacy Policy and applicable Pakistani laws. • QarzMitra App may disclose user data in the following limited circumstances. The Borrower data is shared strictly under Clause 7 with: i. CIBs and KYC & Identity Verification (State Bank of Pakistan and NADRA) ii. Legal Obligations (Government, authorities, Courts) iii. Authorized IT and recovery service providers under NDAs iv. Insurance companies only for loan default protection v. Credit checks by Licensed Credit Bureaus vi. Loan Recovery by authorized agents vii. Tech Support by Third-party service providers QarzMitra App may use the collected information to provide, customize, and improve QarzMitra App services. This includes understanding how and when the borrower uses the services. QarzMitra App undertakes to never share, rent, or sell borrowers’ personal information in any unlawful way. 4. Storage and Protection of Information QarzMitra App upload borrowers’ information to the QarzMitra App Loans secure center(https://arzs.qarzqarzsafety.com/) for encryption and ensure it is never disclosed without permission. QarzMitra App commit to collecting this information only with the borrower’s explicit consent when the borrower use the app. The borrower, If wish to delete the collected information, can contact QarzMitra App via email, and QarzMitra App will proceed with the deletion process. Data is retained during the contract and as long as required for compliance, legal, and audit purposes. Following Clause 8, secure deletion protocols and audit logging are in place to ensure proper purging of data post-use or after a cooling-off withdrawal. Upon request or inactivity, data may be purged in accordance with Clause 8(a)(v). As required under Clause 8 of Circular 12 and the corresponding checklist in Circular 14 following measures are used for the protection of data; • Encryption • Secure Access Management • Session Management • Patch & Vulnerability Management • Cloud Hosting in Pakistan only 5. Link to other websites or applications The QarzMitra App might share its promotion links on other websites for promotion, however, such links are only for advertisement, Therefore, the borrowers are advised to be aware that these other websites may collect borrowers’ personally identifiable information. QarzMitra App is not responsible for the privacy practices or content of these linked websites. In view thereof, it is recommended that the borrower should only apply QarzMitra App on Google Play to ensure the safety of personally identifiable information. 6. Cookies When a borrower uses QarzMitra App services, small data files called cookies are saved on borrower’s device. These cookies usually contain identifiers, site names, and a few numbers and characters. Their main function is to enhance borrowers’ experience with QarzMitra App Loans products and services. QarzMitra App undertakes not to use cookies for any purposes beyond this policy. The borrower can manage or delete cookies according to preferences, but this may affect the functionality of the app. 7. Data Retention and Deletion The borrower can control the information shared within the app and manage preferences. The App could be deleted from the borrower’s device If the borrower chooses not to use the app anymore. The borrower can delete the account in the following ways: 1. Borrower can apply the delete option through the account deletion process within the APP; 2. The borrower can delete the account through the data deletion link QarzMitra App provides on Google Play. Notwithstanding provided hereinabove, in case of an outstanding loan, the borrower’s account cannot be deleted. 8. Revoking Consent The borrower can request the deletion of personal information in the following circumstances: • If QarzMitra App violates laws or agreements when collecting or using personal information; • If QarzMitra App shares or transfers the borrower’s personal information in violation of laws or agreements, then QarzMitra App will stop such actions and notify third parties to delete the information; • If QarzMitra App discloses the borrowers' personal information in violation of laws or agreements. In such a case QarzMitra App will stop the disclosure and request deletion; • If the borrower no longer uses QarzMitra’s products or services, or QarzMitra App have deactivated the borrower’s account, or QarzMitra App terminates services and operations. In these cases, the borrower have the right to request deletion, and QarzMitra App will promptly respond and take appropriate action. 9. Changes to the Privacy Policy QarzMitra App recognizes the importance of updating privacy policies for users. To provide better services, QarzMitra App reserves the right to update the privacy policy. QarzMitra App will notify the borrower of any changes through a new policy. QarzMitra App undertake not to reduce user rights through these updates. 10. Protection of Minors QarzMitra App 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 from using QarzMitra App services. 11. Disputes and Grievance Redressal 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, QarzMitra App asks the borrower to first submit any such complaint directly to QarzMitra’s relevant customer services desk or helpline. QarzMitra App shall deal with the complaints through a comprehensive Grievance Redressal Mechanism and monthly reports shall be submitted with the SECP in compliance with the requirements contained under Clause 4 of the Circular No. 12 of 2024. As required under Clause 4 and Circular 24 of 2018, QarzMitra App maintains a full grievance system. Monthly SECP reports include complaint count, resolution time, and satisfaction metrics. Complaints are filed via app, web, or helpline. Contact Us Company Information: App Name: QarzMitra Company Name: FINTECH GHARANA FINANCIAL (PRIVATE) LIMITED Main Business: Financial lending Company Status: NBFC (Non-Banking Financial Company providing investment and lending services) License Number: No.SECP/LRD/131/FGFPL/2025 If you have any questions, feel free to contact us at: - Email: cs@fintechgharanafinancial.com - Working Hours: Monday to Sunday, 9:00 AM - 5:30 PM - Address: Office No.5B, Mezzanine Floor, Al Malik Centre, Jinnah Avenue, Blue Area, Islamabad QarzMitra value borrower’s privacy and thank you for reading our privacy policy.