Privacy Policy

1. GENERAL

1.1 The website https://butter.money and the mobile application Butter Access (collectively, the “Platform”) are owned and operated by Hanoch Financial Technologies Private Limited, a company incorporated in India under the Companies Act, 2013, having its registered office at Unit 309, 3rd Floor, SAS Tower, Tower A, Sector 38, Gurugram, Haryana - 122001, India (CIN U66190HR2024PTC127043) (“Butter Money”, “Company”, “we”, “us”, or “our”).

1.2 The Company operates as a Direct Selling Agent (DSA) and authorised channel partner of banks, Non-Banking Financial Companies (NBFCs), and Housing Finance Companies (HFCs) regulated by the Reserve Bank of India (“RBI”). The Company is not a lender and does not lend, underwrite, sanction, disburse, or determine the terms of any loan. All lending is carried out solely by the partner lenders, who hold the requisite RBI licences. The Company’s role is limited to customer sourcing, eligibility assessment, lender matching, and referral (the “Services”).

1.3 This Privacy Policy (“Policy”) governs the collection, storage, use, processing, and disclosure of information provided by, or collected from, any person who accesses or uses the Platform or the Services (“you”, “your”, or “User”).

1.4 This Policy is published in accordance with the Information Technology Act, 2000 and the rules made thereunder, the Digital Personal Data Protection Act, 2023 (“DPDP Act”), and applicable RBI guidelines.

1.5 By accessing or using the Platform or the Services, or by otherwise providing your information to us, you consent to this Policy. If you do not agree to this Policy, you must refrain from using the Platform and the Services.

2. INFORMATION WE COLLECT

2.1 Personal Information. Information that identifies, or can reasonably be used to identify, you, including your name, telephone number, email address, mailing and billing address, job title, username, contact preferences, and authentication data.

2.2 Financial Information. Where you apply for or express interest in loan-related Services, financial documents and information including Income Tax Returns, bank statements and transaction records, salary and employment documents, Form 16 and other tax documents, credit reports and credit scores, property and investment documentation, income and employment verification documents, and asset and liability statements.

2.3 Non-Personal Information. Information collected automatically that does not by itself identify you, including IP address, browser and device characteristics, operating system, language preferences, referring URLs, device identifiers, location data, and usage data relating to the Platform.

2.4 Device Permissions. Where you use the App, we may request access to your device camera (to capture or upload documents), notifications, and, where granted by you, location. You may manage or revoke such permissions through your device settings; certain features may not function as a result.

3. USE OF INFORMATION

3.1 We process your information for the following purposes:

to create and authenticate your account and provide access to the Services;
to assess indicative eligibility and creditworthiness;
to generate and present loan offers and recommendations from partner lenders;
to share relevant information with partner lenders and credit information companies for loan evaluation and processing;
to respond to inquiries and provide support;
to send administrative information, updates, and security alerts;
to detect, prevent, and address fraud, security incidents, and prohibited activity;
to comply with legal, regulatory, and statutory obligations; and
to operate, evaluate, and improve the Platform, the Services, and our communications.

4. CONSENT

4.1 We process your Personal Information and Financial Information with your consent and in accordance with the DPDP Act, the Information Technology Act, 2000, and applicable RBI guidelines.

4.2 By using the Services, you consent to the collection, use, and disclosure of your information to our partner lenders, credit information companies (including RBI-licensed credit bureaus such as CIBIL), and service providers, for the purposes of sourcing, eligibility assessment, and loan processing.

4.3 You may withdraw your consent at any time by written notice to the Grievance Officer (Clause 12). Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal and may limit our ability to provide certain Services.

5. DISCLOSURE OF INFORMATION

5.1 Lending Partners. We disclose your Personal Information and Financial Information to our partner banks, NBFCs, and HFCs — which currently include State Bank of India, ICICI Bank, HDFC Bank, Federal Bank, Bajaj Housing Finance, IndusInd Bank, Piramal Finance, and Vridhi Finserv Home Finance (as updated from time to time) — to facilitate evaluation, processing, and the provision of loan offers. Each lender’s use of such information is governed by that lender’s own privacy policy and applicable RBI regulations.

5.2 Credit Information Companies. We may share information with, and retrieve information from, RBI-licensed credit information companies to assess eligibility and creditworthiness.

5.3 Service Providers. We may disclose information to third-party vendors, service providers, and contractors who perform functions on our behalf (including data analytics, communication tools, data storage, payment processing, and marketing), limited to the information reasonably necessary for the relevant function and subject to obligations of confidentiality.

5.4 Legal and Regulatory. We may disclose information where required to comply with applicable law, regulation, legal process, or governmental or regulatory request, or to protect our rights, prevent fraud, or ensure user safety.

5.5 Business Transfers. In connection with any merger, reorganisation, or sale of assets, your information may be transferred to the successor entity, which shall remain bound by protections consistent with this Policy.

5.6 International Transfers. Your information may be transferred to, stored in, or processed in jurisdictions other than your country of residence, subject to appropriate safeguards in accordance with applicable law.

6. COMMUNICATIONS CONSENT (DND)

6.1 Where you provide your telephone number, you authorise us and our partner lenders to contact you by call, SMS, email, or messaging applications in connection with the Services, including where your number is registered under the national Do-Not-Disturb registry, to the extent permitted by applicable law. You may withdraw this authorisation at any time using the opt-out mechanisms provided or by contacting us.

7. COOKIES AND TRACKING TECHNOLOGIES

7.1 We may use cookies and similar technologies to operate and improve the Platform. You may manage your preferences through your browser settings; disabling cookies may affect certain functionality.

8. DATA SECURITY

8.1 We maintain appropriate technical and organisational measures, including encryption, access controls, and operational procedures, to protect your information against unauthorised access, disclosure, alteration, and destruction. No method of transmission or storage is entirely secure, and absolute security cannot be guaranteed.

9. DATA RETENTION

9.1 We retain your information only for as long as necessary for the purposes set out in this Policy, or for such a longer period as required or permitted under applicable law or regulatory requirement.

10. YOUR RIGHTS

10.1 Subject to applicable law, including the DPDP Act, you have the right to access, correct, update, and complete your Personal Information; to request its erasure; to withdraw consent; to nominate another individual to exercise your rights in the event of death or incapacity; and to grievance redressal under Clause 12. You may exercise these rights, or opt out of marketing communications, by contacting us at the details below.

11. CHILDREN

11.1 The Services are not directed to individuals under 18 years of age. We do not knowingly collect Personal Information from such individuals. If we become aware that we have done so, we will take steps to delete it.

12. GRIEVANCE REDRESSAL

12.1 In accordance with the Information Technology Act, 2000, the DPDP Act, and applicable RBI guidelines, complaints or concerns regarding your information or this Policy may be addressed to our Grievance Officer:

Name: Ankita Singh

Designation: Head - Operations and Compliance

Email: [email protected]

Address: Unit 6, B-Block, No.112, AKR TECH PARK, Kudlu Gate, Krishna Reddy Industrial Area, Hosapalaya, Muneshwara Nagar, Bengaluru, Karnataka 560068

12.2 Upon receipt of a complaint, an acknowledgement shall be issued, and the complaint shall be redressed within 15 working days, excluding time taken by you to provide requested information and any delay attributable to a third party.

13. GOVERNING LAW

13.1 This Policy is governed by and construed in accordance with the laws of India. Any dispute arising out of or in connection with this Policy is subject to the exclusive jurisdiction of the courts at Bengaluru, Karnataka.

14. AMENDMENTS

14.1 We may amend this Policy from time to time. The amended Policy shall be effective upon posting on the Platform, with the “Last updated” date revised accordingly. Your continued use of the Platform or the Services constitutes acceptance of the amended Policy.