PRIVACY POLICY

Effective date: May 20, 2026

This Privacy Policy applies to the mobile application Capital Trade Loan and the related website and services (collectively, the "Platform"). The Platform is owned and operated by Capital Trade Links Limited (CIN: L51909DL1984PLC019622), Office No. 102-103, 1st Floor, Surya Kiran Building, 19 K.G. Marg, C.P. New Delhi - 110001, India ("Capital Trade Links Limited", "we", "us" or "our").

Capital Trade Links Limited provides lending and related financial services in India. This Privacy Policy is published in accordance with applicable Indian laws, including the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

By using the Platform, you agree to the collection, use, storage, sharing and protection of your information as described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not access, install or use the Platform.

INFORMATION WE COLLECT

We collect information that is necessary to provide loan application, identity verification, customer support, repayment and account management services. We do not collect information that is not required for these services.

Information you provide to us

• Full name, mobile number, email address, gender and date of birth.
• Current address, permanent address, education details, employment details and income details.
• PAN, Aadhaar-related information when lawfully provided by you, and other identity or KYC information.
• Selfie, live face image, KYC document images and other documents submitted for loan or verification purposes.
• Bank account details, IFSC, repayment details, loan application details, loan agreement details and transaction records.
• Reference contact details that you manually enter in the app, such as name, relationship and phone number. We do not read or upload your phone contacts or address book.
• Information you provide when contacting us by email, phone, forms, customer support or other channels.

Information collected automatically or from the device

• App and service usage information, such as pages viewed, loan process status, button interactions, request time, error logs and similar operational information.
• Network information required for connectivity and fraud prevention, such as IP address and basic request metadata.
• Device information required for security and risk controls, such as device manufacturer, device model, operating system name and operating system version.
• A locally generated app installation identifier used for account security, fraud prevention and service continuity. We do not use Android ID, Advertising ID, IMEI, IMSI, SIM serial number or hardware serial number as a persistent device identifier.

Information from third parties

• Credit report, credit score, fraud check, KYC verification, bank verification and identity verification information from regulated financial institutions, credit information companies, KYC providers and authorized service providers, where permitted by law and based on your loan application or consent.
• Information required by our lending partners, banking partners, payment partners or regulators to process, approve, disburse, service or recover a loan.

DEVICE PERMISSIONS

The app requests only the permissions required for its core loan and account features. You may deny or revoke permissions from your Android device settings, but some features may not work without the required permission.

• Camera: used only when you choose to capture KYC documents, selfies or liveness verification images. Camera images are used for identity verification, fraud prevention and loan processing.
• Notifications: used to show service messages such as loan status, repayment reminders and account-related alerts. You can disable notifications in device settings.
• Internet and network state: used to connect securely to our servers and provide app functionality.

We do not request or collect SMS messages, call logs, precise location, background location, installed app lists, phone contacts, Advertising ID, microphone audio, calendar data or files unrelated to documents that you choose to submit for KYC or loan processing.

HOW WE USE YOUR INFORMATION

We use your information for the following purposes:

• To register and authenticate your account using OTP and other verification methods.
• To receive, assess, process, approve or reject loan applications.
• To perform KYC, identity verification, liveness checks, fraud prevention and credit risk assessment.
• To facilitate loan agreement signing, disbursement, repayment, support, complaint handling and account servicing.
• To communicate with you about your account, loan application, repayments, policy updates, support requests and legally required notices.
• To comply with applicable laws, court orders, RBI guidelines, KYC/AML requirements, audit requirements and requests from lawful authorities.
• To maintain security, prevent unauthorized access, detect misuse and protect the rights, property and safety of users, Capital Trade Links Limited and lending partners.
• To improve app reliability, diagnose technical problems and maintain our services.

HOW WE SHARE INFORMATION

We share your information only when necessary for the purposes described in this Privacy Policy and subject to applicable law and confidentiality obligations. We may share information with:

• Our regulated lending partners, banks, NBFCs and financial service providers for loan application, underwriting, disbursement, servicing, repayment and recovery.
• Credit information companies, KYC providers, identity verification providers, fraud prevention providers, payment providers, DigiLocker or similar authorized verification partners.
• Technology, cloud hosting, customer support, analytics limited to service reliability, document processing, storage and security service providers who process information on our behalf.
• Government authorities, regulators, courts, law enforcement agencies or auditors where disclosure is required by law or necessary to protect legal rights.
• Successors or affiliates in connection with a merger, acquisition, restructuring or transfer of business, subject to continued protection of your information.

We do not sell your personal information. We do not share your data with advertising networks or analytics SDKs for behavioral advertising.

COOKIES AND WEBSITE DATA

Our website may use cookies or similar technologies to operate the website, remember preferences, understand page performance and improve user experience. You can disable cookies in your browser settings, but some website features may not work properly.

DATA SECURITY

We use reasonable administrative, technical and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, misuse or loss. These safeguards include secure transmission using HTTPS/SSL, access controls, authorization controls, restricted internal access, contractual confidentiality obligations and security monitoring.

No method of transmission or storage is completely secure. You are responsible for keeping your mobile device, OTPs and account credentials secure and for notifying us promptly of any suspected unauthorized use.

DATA RETENTION AND DELETION

We retain personal information only for as long as necessary to provide services, comply with legal and regulatory obligations, resolve disputes, enforce agreements, prevent fraud and maintain business records. KYC, loan, repayment, complaint, audit and transaction records may be retained for the period required under applicable law, RBI guidelines, lender requirements and our record retention policy.

You may request access, correction, deletion or withdrawal of consent by contacting us. Deletion or withdrawal may limit or prevent use of our services and may not affect records that we are required to retain for legal, regulatory, audit, fraud prevention, dispute resolution or loan servicing purposes. Where deletion is permitted, we will process the request within a reasonable period after verifying your identity.

YOUR CHOICES AND CONTROLS

• You can choose not to provide optional information, but this may limit app functionality or loan eligibility.
• You can manage app permissions such as Camera and Notifications in Android settings.
• You can uninstall the app at any time.
• You can contact us to request access, correction, deletion, withdrawal of consent or grievance support.

THIRD-PARTY WEBSITES AND SERVICES

The Platform may contain links to third-party websites or services. Their privacy practices may differ from ours. We are not responsible for the privacy practices, content or security of third-party websites or services that are not operated by us.

CHILDREN'S PRIVACY

The Platform is intended for adults who are eligible to apply for financial services. We do not knowingly collect personal information from children.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. Updates will be posted on this page with a revised effective date. Please review this page periodically for the latest information about our privacy practices.

GRIEVANCE OFFICER AND PRIVACY CONTACT

For questions, requests or complaints regarding this Privacy Policy or our handling of your information, please contact us:

Company Name: Capital Trade Links Limited
Address: Office No. 102-103, 1st Floor, Surya Kiran Building, 19 K.G. Marg, C.P. New Delhi - 110001, India
Email: info@capitaltrade.in
Phone: 7042353322
Time: Mon - Sat (10:00 - 19:00)

The Company is based in India. This Privacy Policy is governed by applicable laws of India.