True Credits Private Limited - Privacy Policy

This Privacy Policy of True Credits Private Limited (a company incorporated under the Companies Act, 2013 having its registered office at Huda City Centre Metro Station, 5th floor, sector – 29, Gurgaon, Haryana 122001, India (in any case, hereinafter referred to as “TC”, “True Credits” “we”, “our” or “us”), is an electronic record in the form of an electronic contract formed under the Information Technology Act, 2000 and the rules made thereunder and the amended provisions pertaining to electronic documents / records in various statutes as amended by the Information Technology Act, 2000. The term “you”, “ customer” “user”, “borrower” denotes the person avails the services of True Credits by using the mobile application or through any other mode. This privacy policy does not require any physical, electronic, or digital signature.

This Privacy Policy is a legally binding document between you and True Credits. The terms of this Privacy Policy will be effective upon your acceptance of the same by availing its services. This Privacy Policy specifies the terms related to the management and handling of personal information of users (hereinafter referred to as “the Users”) using the services of True Credits platform accessible through Mobile/Smartphone application (hereinafter “True Balance Application”). We understand that you entrust us with certain Information to help us provide various Services. In exchange for your trust, you expect and deserve our commitment to treat your Information confidential with respect and in accordance with the terms of this Privacy Policy (“Privacy Policy”).

The Privacy Policy describes the policies and procedures followed by True Credits with respect to collection, use and disclosure of your Information and other data that we gather when you register for using our True Balance Application and Services by creating a user account (“Account”), interact with other Users and third party websites and services. This document is published and shall be construed in accordance with the provisions of the Information Technology (reasonable security practices and procedures and sensitive personal data of information) Rules, 2011 under Information Technology Act, 2000; that require publishing of the Privacy Policy for collection, use, storage and transfer of sensitive personal data or information.

Please read this Privacy Policy carefully. By using the website/mobile application, you indicate that you understand, agree and consent to this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not use our Application or website. You hereby provide your unconditional consent or agreements to as provided under section 43a and section 72a of Information Technology Act, 2000.

When you use, download and access the True Credits by using True Balance Application, you are consenting to the collection, transfer, storage, disclosure and other uses of your Information as described in this Privacy Policy.

True Credits complies with all regulations on the protection of Personal Information specified in laws and regulations applicable to information and communication service providers. The Personal Information Policy of the services of True Credits is as follows:


A. Type of Personal Information collected and Purpose and Use of collection

Personal Information is information collected to uniquely identify or contact You. True Credits collects and uses your minimum necessary Personal Information for the list of identified purposes below. The Personal Information will not be used for purposes other than providing its services. Prior approval of the users would be required, in case of change in the purposes .Personal Information for the purposes of this Privacy Policy shall include, but not be limited to:

Name, Phone number, Email address, Geo-tagging, List of Contact, Logs, IP address, Device ID, Country of origin, Gender, Date of Birth, One of Officially Valid Documents specified in RBI-KYC directions (Driving License, Voter’s ID, NREGA Job Card, Passport etc.), Credit and debit card number(last 4 digits), Deposit, charge and transaction information, and any other KYC(Know Your Customer) information required by law to provide True Credit’s Services

Enhanced functionality and improved Service: Records of purchase for goods and service through the app, Type and version of the internet browser/operating system, Type and manufacturer of the mobile phone, Name and Version of system and application software; Other information collected at the time of installation: Installed applications on User’s device; and contact list.

True Credits website enrollment, mobile app, written form, fax, telephone, e-mail, electronic board, promotional offer participation, customer support. Voluntary provision from the Users through service availing.

We may receive Personal information about you from third parties, such as social media services, commercially available sources and business partners. If you access Website through a social media service or connect a service on Website to a social media service, the information we collect may include your user name associated with that social media service, any information or content the social media service has the right to share with us, such as your profile picture, email address or friends list, and any information you have made public in connection with that social media service. When you access the Website through social media services or when you connect any Website to social media services, you are authorizing True Credits to collect, store, and use and retain such information and content in accordance with this Privacy Policy.

B. Term of retaining and use of personal information

True Credits is concerned regarding the Personal Information provided by you for the services of the company. By agreeing to the terms and conditions you have agreed to give us the information, according to the applicable law. True Credits retains Personal Information for a period of at least 10 (ten) years. After that, Personal Information will be promptly disposed when the purpose of collection and usage of the Personal Information is achieved.

True Credits collects and also stores the information so that the user can view the details of transactions done by him, using its services. To improve the Services of the Company, we may also require the log information, to determine the usage of our services and can bring to the customers better services with updates, according to the customer preference.

We at True Credits also use your correspondence information, in order to determine your preference and your feedback to improve onto our services. True Credits uses the information to complete your registration process and other services requested by you. Also the information is used to provide you with a detail account of your account and also help us detect and protect users and ourselves against errors, fraud, or other criminal activity.

The data that we collect using the cookies, assist us in understanding the user trends and to improve according to the customer preferences.True Credits at times collects the information in the form of profiles, in order to customise the services according to the usage. It is to be clarified that the information that is collected by True Credits, will be the property of the company and can be used by it.

C. Term of retaining and use of personal information

We, at True Credits second to none in protecting your information to all extent and therefore do not disclose or share your information with any third party, until it is important for us in order to provide you with desired services. You further agree that such disclosure, sharing and transfer of Your Personal Information shall not cause any wrongful loss to You or to any third party, or any wrongful gain to us or to any third party.

You hereby unconditionally agree and permit that except as otherwise provided under this Privacy Policy, True Credits will disclose your Personal Information to third parties only in the following limited circumstances:

  1. We may transfer, share, disclose or part with all or any of Your Information, within and outside of the Republic of India to various third party service providers / partners / banks and financial institutions for one or more of the Purposes or as may be required by applicable law. In such case we will contractually oblige the receiving parties of the Information to ensure the same level of data protection that is adhered to by True Credits under applicable law

  2. if you use the Service of third parties through the True Credits Application, True Credits may disclose your Personal Information to the associated third-party service providers to facilitate/enhance/complete the Services offered.

  3. to trusted partners who work on behalf of or with us under confidentiality/non-disclosure agreements. These entities may use your Personal Information for performing marketing services, delivering goods, administering promotions, analyzing data and usage of the Service through the True Balance Application, processing credit/debit card payments, operating the Service or providing support and maintenance services for the same, or providing customer service.

  4. You agree that We use other third parties such as a credit/debit card processing company, payment gateway, pre-paid cards etc. to enable You to make payments for availing Services on Application. When You sign up for these Services, you may have the ability to save Your card details for future reference and faster future payments. In such case, we may share Your relevant Personal Information as necessary for the third parties to provide such services, including your name, residence address and email address as available in our records. The processing of payments or authorization is solely in accordance with these third parties’ policies, terms and conditions and we are not in any manner responsible or liable to You or any third party for any delay or failure at their end in processing the payments.

  5. We may also share the information with the government authorities or courts, pursuant to applicable laws and directives, for any investigation for offences in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of various terms and conditions or our policies.

  6. when we have your consent to otherwise share the information.



D. Security of Personal Information

The security of your Personal Information is very crucial to us. It is our endeavor to protect your Personal Information against any type of unauthorized usage. To do this ,True Credits has adopted measures like internal reviews of the data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized system access where your personal information is stored. True Credits has taken every measure applicable under law to protect your information.

We take security procedure and technical and organizational measures to safeguard your Personal Information. To name a few, firewalls, browser certification technology, encryption, limited access, use of passwords, for better safety of the information given by you.

If you take the payment gateway to make payments then the credit/debit card being used by you will be stored in compliance with industry standards/ recommended data security standard for security of financial information such as the Payment Card Industry Data Security Standard (PCI-DSS).

True Credits may share information with other third parties under strict confidential/Non-disclosure agreement, but won’t be liable for the security breach of the third party. True Credits cannot also be held responsible for the loss or damage to you, as a result of you providing the information to third parties.

Notwithstanding anything contained in the policy, True Credits won’t be responsible for any loss or damage to you in case of any Force Majeure Event, which is unforeseeable or not within the control of True Credits. A Force Majeure Event shall mean any event that is beyond the reasonable control of True Credits and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, unauthorized access to computer, computer system or computer network, computer crashes, breach of security and encryption (provided beyond reasonable control of True Credits), power or electricity failure or unavailability of adequate power or electricity.

You agree that no transmission on the internet can be said to be fully secured, hence, True Credits cannot ensure the security of all the information provided by you and you do it on your own accord. True Credits may entrust a third person with the management affairs of personal information for successful service operation and contract performance to following entities, and will manage trustee to protect Personal Information from theft, leak, loss, falsification, harm in accordance with applicable laws and regulations.


E. Method Of Disposal Of Personal Information

a. Procedure of disposal

To protect the information entered by Users is immediately disposed off after the purpose of its collection has been fulfilled, in accordance with the corporate policy and other applicable laws. The above information, unless otherwise required by law, shall not be used for any other purposes, other than the original purpose.


b. Method of disposal

Personal information printed on paper is shredded or incinerated for disposal. Personal information saved in a digital format is deleted by using technology that prevents the recovery of deleted records.


F. Installation And Operation Of Automatic Personal Information Collection Systems And Refusals

True Credits automatically collects device ID and access log to be used to provide personalized services and offer improved user experience.



G. Measures for The Protection Of Personal Information

True Credits takes the following technical, administrative, and physical measures to prevent the loss, theft, leakage, external attacks on and hacking of information, and aims to have the highest level of security in relation to the processing of the personal information of the Users.

a. Minimizing the number of managers processing personal information

True Credits minimizes the number of managers processing personal information.


b. Encryption of personal information

Password of User is managed and stored in encrypted manner. Confirming and changing password is only possible by the User who knows correct password.


c. Technical measures against hackings, etc.

True Credits uses anti-virus solutions and inspects the solution on regular basis to prevent damages from computer viruses and hackings. True Credits also uses technical and physical measures including installation of systems with limited external access.


d. Promoting Awareness among the staff

Staff will be trained on the privacy policy and its implications. At the time of appointment, each staff will be made to sign a non-disclosure/confidentiality clause, thereby agreeing to protect True Credit and its clients’ data.


e. Managing IDs and passwords

ID and password of a User can be used by the Authorized User only. True Credits is not responsible for personal information leakage by negligent act of the User or accidents from inherent weakness of the Internet.


f. Information Security

True Credits takes the security of its User’s information seriously. True Credits protects the User’s information using data security: encryption and a Secure Sockets Layer (SSL) protocol. This creates an encrypted connection between the User and True Credits servers. True Credits assumes no liability for any disclosure of information due to errors in transmission, unauthorised third party access or other acts of third parties, or acts or omissions beyond its reasonable control and the User agrees not to hold True Credits responsible for any breach of security unless such breach has been caused as a direct result of gross negligence or willful default.


g. Due Diligence & Security

Data security is our priority. In order to prevent unauthorized access, we have the required procedures and firewalls (both electronic and physical) to safeguard your data



H. Security Operation Center

True Credits use SOC (Security Operation Center) System to identifying the Security incident to True Credits internal systems. The security of Your Personal Information is crucial to us. We at True Credits focus on protecting your personal information against any type of unauthorized usage. We have adopted measures like internal reviews of the data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized system access where your personal information is stored.

You agree that measures adopted are secured and adequate. We restrict access to Your Personal Information to us and our affiliates’ employees, agents, partners, and agencies who need to know such Personal Information in relation to the purposes as specified above in this Privacy Policy, provided that, such entities agree to abide by this Privacy Policy.

While it is our endeavour to take all reasonable and appropriate steps to keep secure any information which We hold about You and prevent unauthorized access, You acknowledge that the internet is not 100% secure and that We cannot provide any absolute assurance regarding the security of Your Personal Information.



By submitting your personal information, you consent to the use of that information by us as detailed in this policy.




In relation to the payment gateways used by you to do payments to different sites or for the services, these gateways are managed by the third parties and hence are controlled by the same. At some point some of the information is saved in these third party sites. True Credits is not responsible for any type of loss or damage to you, with regard to the information held by these third party sites. However, these payment gateways are digitally encrypted, thereby providing the highest possible degree of privacy, security and care.

True Credits is not in any way responsible for the third party sites and the privacy policy doesn’t cover them. For the same you will have to read the specific privacy policy of the third party sites.

We are not in a position to control or guarantee the accuracy, integrity, or quality of the information, data, text, software, music, sound, photographs, graphics, videos, messages or other relevant materials available on the Linked Sites.To clarify, please be aware that the information you provide on the Linked Sites shall be governed by policies of the Linked Sites which you view.


K. Administrators in Charge of Management of Personal Information

True Credits will designate an administrator in charge of the management of the personal information of Users, and strive to protect the personal information. He/she may be accessed as under:

Address :Huda City Centre Metro Station, 5th floor, sector – 29, Gurgaon, Haryana 122001, India

e-mail : cs@truecredits.in



This Policy shall be governed by and construed in accordance with the Indian laws The courts at Gurgaon (HR) shall have exclusive jurisdiction in relation to any disputes arising out of or in connection with this Policy.

If any dispute arises between True Credits and the User in connection with or arising out of the validity, interpretation, implementation or alleged breach of any provision of the Policy, such dispute shall be referred to and finally resolved by arbitration in accordance with the Indian Arbitration and Conciliation Act, 1996 for the time being in force, which rules are deemed to be incorporated by reference in this clause. There shall be one (1) arbitrator and the seat of the arbitration shall be Gurgaon, India.


M. Right of Users

Users have the right, at any time, to know whether their personal information has been stored and can consult True Credits to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for transformation into anonymous format or to block any data Requests should be sent to the administrator in charge of the management of the personal information of Users at the contact information set out above

This Application does not support “Do Not Track” requests. To determine whether any of the third-party services uses honor the “Do Not Track” requests, please read their privacy policies.



We may amend, alter, modify or update the Privacy Policy from time to time and same would be conveyed to you by posting a mail and also by posting it as a notice on the website and Application, along with the link to the updated policy, so that you may be aware of the information we collect and how we use it at all times. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. Users are bound by any changes to the Privacy Policy when they continue to use the Website(s) and/or Application(s) after such changes have been first posted.




In accordance with Information Technology Act, 2000 and rules made there under, in case of grievances you can contact cs@truecredits.in


In the event you wish to make a complaint regarding any violation of the provisions of the Privacy Policy, you may send a written complaint to the above mail id ,which shall be redressed within one (1) month.



This privacy policy takes effect from June 19, 2020.