Privacy Policy.

1. Who we are

A.T.N. Leasing & Finance Ltd. ("ATN", "we", "us" or "our") is a Non-Banking Financial Company registered with the Reserve Bank of India (Registration No. B-14.01797). We are the data fiduciary for the personal data described in this policy.

This Privacy Policy explains what personal data we collect when you use our website and services, why we collect it, who we share it with, how long we keep it and the rights you have. It is published in line with the Digital Personal Data Protection Act, 2023, the Information Technology Act, 2000 and the rules under it, and RBI's guidelines on digital lending.

2. Your consent

We collect and use your personal data only with your consent, given through a clear and specific request, or where the law otherwise permits it (for example, to meet KYC and regulatory obligations). You can withdraw your consent at any time, as explained in "Your rights" below. Withdrawing consent does not affect processing already carried out, and we may still need to keep some data to service an active loan or meet legal requirements.

3. What we collect

• Identity and contact details: name, date of birth, gender, photograph, PAN, Aadhaar (masked, or as permitted by law), address, mobile number and email address.
• Employment and financial details: employer, salary, salary slips, bank account details and bank statements (shared directly by you or, with your consent, through an Account Aggregator).
• Credit information: your credit report and score from credit information companies, obtained with your consent.
• KYC data: information received from DigiLocker, Aadhaar-based e-KYC or video KYC, including a live photograph or video where required.
• Loan and payment data: your applications, offers, agreements, repayments and communications with us.
• Technical data: IP address, device and browser type, approximate location and how you use our website, collected through cookies and similar technologies.

We do not access your phone's contact list, call logs, photo gallery or personal messages.

4. How we use your data

• to verify your identity and complete KYC as required by RBI;
• to assess your eligibility and creditworthiness and make a lending decision;
• to prepare your Key Fact Statement and loan agreement, disburse your loan and collect repayments;
• to send you service messages, reminders and, if you agree, offers;
• to prevent fraud, money laundering and misuse;
• to report to credit information companies, regulators and authorities as required by law;
• to handle your requests and complaints; and
• to improve our website and services.

5. Who we share it with

We share your personal data only as needed for the purposes above, and only with:

• credit information companies (such as CIBIL, Experian, Equifax and CRIF High Mark);
• KYC, e-sign, e-NACH and Account Aggregator service providers;
• banks and payment gateways that process disbursals and repayments;
• service providers that support our operations, such as cloud hosting, communication and customer support providers, under contracts that require them to protect your data;
• recovery agents we appoint, if a loan becomes overdue, in line with our Fair Practice Code; and
• regulators, courts and law enforcement agencies where required by law.

We do not sell your personal data.

6. Where your data is stored

Your personal data is stored on servers located in India, as required by RBI's guidelines on digital lending.

7. How long we keep it

We keep your personal data only as long as needed for the purpose it was collected for, or as required by law. Loan and KYC records are kept for the period required under the Prevention of Money Laundering Act, 2002 and RBI directions (generally at least five years after the loan relationship ends). After that, data is securely deleted or anonymised.

8. How we protect it

We use reasonable security practices, including encryption of data in transit and at rest, access controls, secure data centres and regular security reviews. No system is completely secure, so please keep your login details and OTPs private. We will never ask for your card PIN, CVV or OTP over a call or message.

9. Cookies

Our website uses essential cookies to work properly and, where you allow it, analytics cookies to help us understand how it is used. You can block or delete cookies in your browser settings; some features may not work without essential cookies.

10. Your rights

Subject to applicable law, you have the right to:

• know what personal data we hold about you and how it is used;
• have inaccurate or incomplete data corrected and updated;
• have your data erased once it is no longer needed, unless we must keep it by law or to service an active loan;
• withdraw your consent for any processing based on consent, including marketing messages;
• nominate a person to exercise your rights in the event of your death or incapacity; and
• raise a grievance with us and, if unresolved, with the Data Protection Board of India.

To exercise any of these rights, write to info@atn-leasing-finance.com. We may need to verify your identity before acting on a request.

11. Third-party links

Our website may link to other websites and services, such as payment gateways and DigiLocker. Their privacy practices are governed by their own policies, which we encourage you to read.

12. Changes to this policy

We may update this policy from time to time. The latest version will always be on this page with its "Last updated" date. If we make significant changes, we will inform you by email or SMS where appropriate.

13. Grievance officer

If you have any question or complaint about how your personal data is handled, contact our Grievance Officer:

[Name of Grievance Officer]
A.T.N. Leasing & Finance Ltd., 2nd Floor, Plot No. 7, Block 2, WHS, Kirti Nagar, New Delhi 110015
Email: info@atn-leasing-finance.com
Phone: [phone number]

We will acknowledge your complaint promptly and aim to resolve it within [X] days. See our Grievance Redressal page for escalation options.