Privacy Policy

1. Introduction & Scope

Triangular Intermediaries Services Pvt. Ltd. (“Triangular Intermediaries”, “Company”, “we”, “us” or “our”) respects your privacy and is committed to protecting the personal information you share with us.

This Privacy Policy explains how we collect, use, store, share and protect personal information when you:

• visit our website or any of its pages;
• submit a loan enquiry, application or consultation request (online, by phone, WhatsApp or at our office);
• use our Customer Login portal;
• apply to become, or work with us as, a DSA partner or connector.

This Policy is published in accordance with the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and the Digital Personal Data Protection Act, 2023 and rules made under it, to the extent applicable. By using our website or services, you acknowledge that you have read and understood this Policy.

2. Who We Are

Triangular Intermediaries is a loan Direct Selling Agent (DSA) and financial services facilitation company based in Hardoi, Uttar Pradesh. We help customers find suitable loan products — including Home Loans, Business Loans, Loan Against Property, Personal Loans, MSME, Professional and Vehicle Loans — from our partner banks and Non-Banking Financial Companies (NBFCs).

For the purposes of data protection law, we act as a Data Fiduciary for the information we collect directly from you. When we forward your information to a lender, that lender processes it under its own privacy policy and legal obligations.

3. Information We Collect

We collect only the information reasonably necessary for the service you request.

A. Loan Applicants & Customers

Financial information such as bank statements and account details is treated as sensitive personal data and handled with additional care.

B. DSA Partners & Connectors

• Name, contact details, address and operating location
• PAN, Aadhaar (masked), photograph and other KYC documents for onboarding
• Bank account details for payment of commission / payout
• GST registration and business details, where applicable
• Referral, lead and application-related records

C. Technical Information

When you visit our website, our hosting server may automatically record technical data such as IP address, browser type, device type, pages visited, date and time of visit, and referring page. This is used for security, troubleshooting and improving the website.

4. How We Collect Information

• Directly from you — through website forms, Customer Login portal, phone calls, WhatsApp, email, or when you visit our office.
• Through social media lead forms — when you submit an enquiry form on our advertisements on Facebook, Instagram or other Meta platforms (see below).
• Through DSA partners / connectors — who refer you to us with your permission.
• From lenders and credit bureaus — such as loan status updates or credit reports, with your authorisation.
• Automatically — technical data when you browse our website.

Facebook & Instagram (Meta) Lead Ads

When you fill an enquiry form on our advertisement on Facebook or Instagram, Meta Platforms shares with us the details you submit in that form — such as your name, mobile number, email, city and loan requirement. Some fields may be pre-filled by Meta from your profile; you can edit them before submitting.

We use this information only to contact you about the loan or service you enquired about, as described in this Policy. We do not receive your Facebook or Instagram password and do not access your account. Meta’s own handling of your data is governed by the Meta Privacy Policy.

If you do not want to be contacted after submitting a lead form, call or email us (Section 21) and we will delete your lead details.

5. Purposes of Use

We use personal information only for the following purposes:

• Responding to your loan enquiry and providing free consultation.
• Assessing which loan products and lenders may suit your profile.
• Preparing, submitting and following up on loan applications with banks and NBFCs on your behalf.
• Verifying identity and documents as required by lenders and applicable KYC norms.
• Sharing application status, updates and service communications with you.
• Onboarding, managing and paying DSA partners and connectors.
• Preventing fraud, misuse and unauthorised access.
• Maintaining records and complying with legal, regulatory, tax and audit obligations.
• Sending information about other loan products, only where you have agreed to receive it.

We will not use your information for any purpose that is unrelated to the above without informing you and, where required, obtaining your consent.

6. Consent

Where we rely on your consent, we will ask for it in a clear manner before collecting or sharing your data — for example, before sending your application to a lender or obtaining your credit report. You may withdraw consent at any time by contacting our Grievance Officer (Section 21). Withdrawal will not affect processing already carried out, but it may mean we cannot continue processing your loan application.

Some processing may also be carried out without consent where permitted by law, such as compliance with a legal obligation or a request from a lawful authority.

7. Credit Information (CIBIL & Other Bureaus)

To check your loan eligibility, we or our partner lenders may obtain your credit report from credit information companies such as TransUnion CIBIL, Experian, Equifax or CRIF High Mark. This is done only with your authorisation.

Your credit report is used only to evaluate suitable loan options, is shared only with the lender(s) you apply to, and is not used for any other purpose. Credit enquiries made by a lender for your application may be reflected in your credit report as per bureau rules.

8. Sharing of Information

We share personal information only to the extent necessary, and only with:

• Banks and NBFCs to which your loan application is submitted, for evaluation, sanction and disbursement.
• Agencies appointed by lenders — such as field verification, valuation, legal and technical agencies — as part of the loan process.
• Credit information companies, with your authorisation.
• The DSA partner / connector who referred you, limited to status updates on that referral.
• Service providers who help us run our business — website hosting, email, cloud storage and communication services — under obligations of confidentiality.
• Government, regulators, courts or law enforcement, where required by law.

9. DSA Partners & Connectors

Information provided by DSA partners and connectors is used for verification, onboarding, lead tracking, communication and payment of commission as per the applicable partner agreement.

Partners must submit a customer's information to us only after informing the customer and obtaining their permission. Partners are required to keep customer information confidential and must not use it for any purpose other than the referral.

Registration as a partner does not guarantee appointment, a DSA code, commission or any volume of business; these are governed by separate written terms.

10. Calls, SMS, WhatsApp & Email

When you submit an enquiry or share your number, you authorise us to contact you by phone, SMS, WhatsApp or email regarding that enquiry, even if your number is registered under DND, for that service-related purpose only.

Promotional messages about other products will be sent only in line with TRAI’s regulations on commercial communications and your consent. You can stop promotional messages at any time by replying “STOP” on WhatsApp, or by calling or emailing us.

Calls with our team may be recorded for quality, training and dispute-resolution purposes.

11. Customer Login Portal

Our Customer Login portal lets you submit applications, upload documents and track status. Please keep your login credentials confidential and log out after use, especially on shared devices. Passwords are stored in encrypted (hashed) form, and our staff can never see your password.

If you suspect unauthorised access to your account, contact us immediately.

12. Cookies

Our website uses essential cookies and browser storage to keep pages working properly, for example to keep you signed in to the Customer Login portal. If we add analytics or advertising tools in the future, we will update this Policy and seek consent where required.

You can block or delete cookies through your browser settings; however, some features such as login may not work without them.

13. Data Storage & Security

We follow reasonable security practices to protect your information against unauthorised access, alteration, disclosure or loss, including:

• HTTPS (SSL) encryption on our website;
• password-protected, role-based access so that only authorised staff can view customer files;
• secure hosting with regular backups;
• confidentiality obligations on employees, partners and service providers.

Your data is stored on the secure servers of our hosting provider. In the event of a personal data breach, we will take prompt steps to contain it and inform affected persons and the relevant authority as required by law.

While we take every reasonable precaution, no method of transmission over the internet or electronic storage is 100% secure.

14. Data Retention

We keep personal information only for as long as needed for the purpose it was collected for:

• Enquiries that do not proceed — deleted after a reasonable period, or earlier on your request.
• Loan applications and partner records — retained for the period required by our agreements with lenders and by applicable tax, accounting and legal requirements.

When information is no longer required, it is securely deleted or anonymised.

15. Your Rights

Subject to applicable law, you have the right to:

• Access — know what personal information we hold about you and with whom it has been shared;
• Correction — ask us to correct or update inaccurate or incomplete information;
• Erasure — ask us to delete your information, unless we must retain it by law;
• Withdraw consent — at any time, for processing based on consent;
• Grievance redressal — raise a complaint with our Grievance Officer;
• Nominate — nominate another person to exercise your rights in case of death or incapacity.

To exercise any of these rights, contact our Grievance Officer (Section 21). We may ask you to verify your identity before acting on a request. Please note that information already shared with a lender is held by that lender; we will forward your request to them where relevant, or you may contact them directly.

If you are not satisfied with our response, you may approach the Data Protection Board of India once it is operational under the Digital Personal Data Protection Act, 2023. For complaints about a loan, sanction or service of a bank or NBFC, you may also use that lender’s grievance process and the RBI Integrated Ombudsman Scheme (cms.rbi.org.in).

16. Fraud Awareness

17. Third-Party Websites

Our website may contain links to third-party websites, including those of banks, NBFCs, social media platforms and WhatsApp. These websites have their own privacy policies, and we are not responsible for their content or practices. Please review their policies before sharing information with them.

18. Children

Our services are intended only for persons aged 18 years or above. We do not knowingly collect personal information from anyone under 18. Where a minor’s information is required as part of a loan (for example, as a co-applicant’s dependent or in property documents), it will be collected only with the verifiable consent of the parent or lawful guardian. If you believe we hold a minor’s information improperly, please contact us and we will delete it.

19. Changes to this Policy

We may update this Privacy Policy from time to time to reflect changes in our services, practices or the law. The updated version will be published on this page with a revised “Last Updated” date. Where changes are significant, we will make reasonable efforts to inform you, for example through a notice on our website.

20. Governing Law & Jurisdiction

This Privacy Policy is governed by the laws of India. Subject to applicable law, any dispute arising out of it shall be subject to the jurisdiction of the competent courts at Hardoi, Uttar Pradesh.

21. Grievance Officer & Contact Us

For any question, request or complaint about this Policy or your personal information, please contact: