A. Introduction
This Privacy Policy (“Policy”) outlines the practices and policies of Spice Bulls Limited (referred to as the “Company,” “We,” “Our,” or “Us,” which also encompasses its subsidiaries) concerning the collection, use, processing, storage, retrieval, disclosure, and transfer of Your (the words, “Yours/ yours”, “Him/ him”, “His/ his”, “You/ you”, “User”, and “Customer” refers to the end user of various services provided by Us) information, including personal or sensitive personal data or information ("Information"). This Information may be received through Your access and utilization of various facilities, services provided by Us (“Services”) through Your access, interaction, or use of Our portal, network, website, or mobile application (“Platform”). It is important to note that the scope of this Policy is confined to the aforementioned Information collected or received by Us through Your use of the Platform or Services.
By accessing or using the Platform or availing the Services, You hereby explicitly and specifically agree to the terms outlined in this Policy. The collection, use, processing, storage, retrieval, disclosure, or transfer of Your Information shall be conducted in accordance with this Policy and in compliance with applicable laws including but not limited to the Digital Personal Data Protection Act, 2023 (“DPDP”), Information Technology Act, 2000 (“IT”), and the rules established thereunder, as may be amended periodically. Additionally, Our practices align with the regulations, directions, circulars, guidelines, or other mandates issued by the Reserve Bank of India ("RBI"), any other regulators in India and any other relevant acts, laws, regulations enacted by the Parliament of India/Government of India (collectively referred to as "Applicable Laws"), that are applicable to the Services available on the Platform.
All terms and conditions, as well as policies governing the use of the Platform (as outlined in the Terms and Conditions or any other policies/terms of the Company), are hereby incorporated into this Policy by reference. We urge You to carefully read this Policy to ensure a clear understanding of how any Information You provide to Us will be handled. Your use of the Platform implies that You have read and accepted this Policy. By accessing or using the Platform or the Services, You explicitly and specifically consent to Our collection, processing, storage, transfer, use, disclosure, and handling of Your Information in accordance with this Policy. If You disagree with the practices outlined in this Policy, kindly refrain from providing Us with Your Information or using, accessing, or interacting with the Platform and/ or availing the Services.
You hereby represent to Company that:
Note: “Personal Information” means the 'personal data' and 'sensitive personal data or information' as defined under the Applicable Laws and as provided by You under the purview of this Policy.
B. What we Collect?
We may collect and/or gain access to and/or record following Information, as disclosed by You to Us:
Note: Users can always refuse to supply Personal Information, however, it may prevent them from access to certain Services related activities.
You have the right to modify, revoke or withdraw Your consent for the collection and use of Your Personal Information at any time as per the procedure prescribed in section K below. However, please note that we will not be able to delete your KYC related information, financial and transaction information as per the applicable guidelines.
C. What we do with the Personal Information We Gather?
We may use Your Personal Information to:
D.1 Collection and Use of Non-Personal Information
We may collect Your non-personal information whenever You use and interact with the Platform. Non-personal information may include the information other than the Personal Information (as indicated above) and may also include browser name, the type of computer, and technical information about means used by You to connect to our Platform, such as the information about the operating system and the internet service providers utilized and other similar information.
This information is aggregated and used to help us provide more useful information to You and to understand which part of the Services and/or the Platform are of Your most interest.
If we do combine non-personal information with Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.
D.2. Sharing of information with Authorities
We may disclose Your Personal Information to the courts, law enforcement agencies, or any other government/regulatory/statutory authority, as required by them in connection with any ongoing proceedings before them.
E. Security
We are committed to ensuring that Your Personal Information is secure. We adopt appropriate data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of Your Personal Information, username, password, transaction information, and data stored in our Platform/ eco-system.
To secure the Personal Information, provided by You, We implement reasonable security practices and procedures as mandated under the IT Laws. We have comprehensive documented information security programme and information security policies that contain managerial, technical, operational and physical security control measures that are commensurate with respect to the Personal Information being collected and the nature of Our business.
You are responsible for the correctness of the Personal Information which You choose to submit to Us.
If You list Your name and email address in a blog/forum posting, then that information is public which will not be under the control of the Company. You are requested to take care when using any such features.
While We try Our best to ensure Your Information is safe and secure, because of the inherent vulnerabilities of the internet, We cannot warrant complete security of all Information that You share with Us.You should understand that there is no such thing as complete security. If We become aware that Your Information has been disclosed in a manner not in accordance with this Policy, We will use best efforts to notify You of the nature and extent of the disclosure (to the extent we know that information) as soon as reasonably possible and as permitted by Applicable Laws.
F. Retention of Personal Information
We will retain Your Personal Information for as long as the purpose for its usage exists and as permitted or prescribed under Applicable Laws. Subsequently, the Personal Information will be erased by Us.
G.1 Sharing Personal Information
We may use third-party service providers to help Us operate Our business and provide Services or administer activities on Our behalf, such as sending out newsletters or surveys. We may share Your Personal Information with these third parties for those limited purposes. We only share the Personal Information on a partial and “need-to-know” basis.
In general, the third-party service providers used by Us will only collect, use and disclose Your information to the extent necessary to allow them to perform the services or activities they provide Us. In such cases, We share the Information securely and use commercially reasonable efforts to ensure that all recipients comply with confidentiality obligations and sign covenants in this regard. However, certain third-party service providers (such as banks, financial institutions, payment aggregators or credit information companies), have their own privacy policies in respect to the information We are required to provide to them. For these third-party service providers, We recommend that You read their privacy policies to understand the manner in which Your Information will be handled by them. Once You leave the Platform or are redirected to a third-party website or application, You are no longer governed by this Policy or the Platform's Terms and Conditions and in such circumstances the privacy policy of such other website will apply. We will not be liable for any acts or omissions of the third-party service provider.
G.2 Disclosures
Following are the third parties to whom Your Personal Information is shared with.
Specific consent for sharing Your Information with third parties, group companies will be sought from You, where so required under Applicable Laws.
We are committed to always keeping all such Information safe and provide the highest possible degree of care available under the technology presently in use. Any sharing of information with third party service providers, group companies shall be under agreements which has confidentiality clauses restricting such parties with regard to the use of such Personal Information and in compliance with the provisions of Applicable Laws.
H. Third Party Websites
You may find advertising or other content on the Platform that link to the sites and Services of our partners, suppliers, advertisers, sponsors, licensors, and other third parties. We do not control the content or links that appear on these sites and platform/ services and are not responsible for the practices employed by those websites and platform/ services linked to or from our Platform. In addition, these sites and platform, including their content and links, may be constantly changing. These sites and platform may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites and platform which have a link to the Services, is subject to that website and such platform’ terms and policies.
We may collaborate with various third parties in connection with the Platform or the provision of Services. It is important to note that once You provide Information to any third party or navigate to third-party links while using the Platform, Our Policy will no longer be applicable, and We disclaim responsibility for the privacy practices of these third parties.
I. Changes to this policy
We reserve the right to change, update, modify, insert, or delete any provision of this Policy, from time to time, at Our sole discretion.
We encourage You to regularly check this page for any changes to this Policy. You acknowledge and agree that it is Your responsibility to periodically review this Policy and stay aware of any modifications.
J. Your Acceptance of These Terms
By utilizing the Services or accessing the Platform, You hereby agree and acknowledge to be bound by this Policy. You provide Your specific and explicit consent that We will collect, use, process, and share Your Personal Information and non-personal information in a manner consistent with the terms outlined in this Privacy Policy. If You do not agree with these terms, please refrain from using the Services. Your continued use of the Platform or Our Services following any change or amendment to this Policy shall indicate Your acknowledgment of such changes and Your agreement to be bound by the terms and conditions of such changes.
You agree that Your consent is given freely, specifically, with informed understanding, unconditionally, and unambiguously. This consent signifies Your agreement to the processing of Your Personal Information by Us for the specified purpose mentioned in this Policy.
K. Your Rights
You have the right to update, revoke, or withdraw Your consent for the collection and use of Your Personal Information at any time. If You wish to do so, You can submit a request to Us at care@spicebulls.com. Upon receiving Your request, We will proceed to update, limit the use of Your Personal Information in Our records as required under Applicable Laws.
Please note that there are certain situations where We may be legally obligated to process or retain Your Personal Information, as required by the Applicable Laws. These records and data shall be made available for scrutiny to regulators or any other investigation agencies as required under Applicable Laws.
Note: Please note that such action may impact Our ability to process or facilitate the use of Your Personal Information, potentially resulting in the discontinuation of the Services for which this Personal Information was being utilized, at Our sole discretion.
By submitting a request at care@spicebulls.com, You may review, correct, complete, or rectify the inaccurate Personal Information that is stored with Us.
You have the right to access the following details about Your Personal Information by submitting a request to care@spicebulls.com:
L. Support and Escalations
For any service related support or for any consent related support as detailed above, please contact or email our customer care at care@spicebulls.com.
Address: 326,Ansal Chambers-II, Bhikaji Cama Place R.K. Puram,
South West Delhi, New Delhi, Delhi, India, 110066.
For escalations with related to privacy concerns, please reach out to our grievance officer, at the contact details as below. Our grievance officer will attempt to expeditiously redress your grievances:
Name - Sanatan Malik
Designation - Grievance Officer
Email - legal@spicebulls.com
326,Ansal Chambers-II, Bhikaji Cama Place R.K. Puram,
South West Delhi, New Delhi, Delhi, India, 110066.
M. Governing Law and Dispute Resolution
Except as otherwise described, all content accessed through the use of the Platform is made available solely to facilitate You. We control and operate the Platform and Services and make no representation that the contents and Services are appropriate or available for use in other locations. If You use the Platform from a location other than where the Platform and Services are controlled and operated, You are responsible for compliance with applicable local laws.
This Policy shall be governed by and shall be construed in accordance with the laws of India. All disputes relating to this Policy shall be subject to the exclusive jurisdiction of the courts at Delhi, India.
Spicebulls Investments Limited (“Spicebulls” or “We” or “Us” or “Our” or “Company” which also includes its affiliates) is registered as a non-banking financial company duly authorized by the Reserve Bank of India (“RBI”) to provide financial services (“Services”). Spicebulls has its registered office at 326, Ansal Chambers-II, Bhikaji Cama Place R.K. Puram, South West Delhi, New Delhi, India, 110066. Using this site by implication, means that user “You/Customer” have gone through and agreed and abide by following terms & conditions (“Terms”).
This document is an electronic record in terms of Information Technology Act, 2000, amendments thereof from time to time and the rules thereunder as applicable and the amended provisions pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signatures.
1. GENERAL
2. Conditions of Use
3. Terms and Conditions for Loan Application
You hereby acknowledge and confirm that:
4. Privacy Policy & Data Protection
5. Proprietary Rights and Licence
6. Availability
7. Limitation of Liability
8. Disclaimer of Warranties
9. Indemnification
You agree to indemnify and hold the Company, its officers, directors, shareholders, employees, sub-contractors, agents, parent companies, sister companies, subsidiaries and other affiliates, indemnified and harmless from any claim or demand, including reasonable attorneys' fees, made by any third party due to or arising out of Your use of the Platform or the Services, any unauthorised use of the Platform or Services by You, Your violation of these Terms, or Your violation of any rights including rights in any form of intellectual property of any third party and/or any violation of applicable law by You.
10. Amendments to The Terms
11. Entire Agreement
The Terms including the Privacy Policy constitutes the entire agreement between You and the Company and governs Your access and use of the Platform and Services, superseding any prior agreements between You and the Company with respect to the Platform and Services. If any provision of these Terms is, or is found to be, unenforceable under Applicable Laws, that will not affect the enforceability of the other provisions of these Terms.
12. Governing Law and Dispute Resolution
Spicebulls Investments Limited publishes the following policies. Please select a policy from the list to view its details:
Spicebulls Investments Limited
Interest Rate Policy
1. Purpose
RBI has directed NBFCs to have a documented Interest Rate Model Policy approved by the Board of Directors which would lay down internal principles and procedures in determining interest rates and other charges on the loan products offered by NBFCs. The Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023 has been referred to formulate this policy.
Spicebulls Investment Limited (hereinafter “Company”), recognizes its role as a corporate entity and endeavors to comply with the RBI guidelines and adopt the best practices with the highest standards of governance through transparency in business ethics, accountability to its customers, government and others.
2. Requirements
The Board of each NBFC is required to adopt an interest rate model taking into account relevant factors such as cost of funds, margin and risk premium and determine the rate of interest to be charged for loans and advances. The rate of interest and the approach for gradations of risk and rationale for charging different rate of interest to different categories of borrowers is to be disclosed to the borrower or customer in the application form and communicated explicitly in the sanction letter.
The rates of interest and the approach for gradation of risks is to be made available on the website of the company or published in the relevant newspapers. The information published on the website or otherwise published is to be updated whenever there is a change in the rates of interest. The rate of interest must be annualised rate so that the borrower is aware of the exact rates that would be charged to the account.
The Company shall ensure fair practice and transparency to its customers and accordingly benchmark floating reference rate.
3. Ownership and Review
3.1. To ensure effective implementation of this Policy, the Board may delegate certain operational aspects to management level Asset Liability Committee (hereinafter “ALCO”) comprising of the Executive Director, CFO and any other leadership members, as deemed fit by the Board and the committee. The ALCO shall review the benchmark rate on a quarterly basis or earlier, if required, and changes proposed, if any, shall be accordingly approved by the ALCO.
3.2. Management teams across businesses can have their internal pricing policies under the overall framework of this Policy for deciding the spreads to arrive at final rate. Any changes to business level internal pricing policies, if any, will be approved by the ALCO.
3.3. The Policy will be reviewed at yearly intervals or as and when considered necessary by the Board. Any change or amendment to this Policy shall at all times comply with the regulatory guidelines.
4. Methodology of Arriving at Interest rate for Loans and Approach for Gradation of Risk
4.1. The Company lends money to its customers through fixed and reducing rate loan. The Company being a diversified NBFC lends money through various products to cater to needs of different category of customers.
4.2. Cost of Funds
4.3. Cost of Liquidity – The Company needs to keep liquidity buffer to manage liquidity risk and this liquidity buffer comes with negative carry on investments if any.
4.4. Cost of Credit – It is the cost of risk which the business carries on account of the creditworthiness of the borrowers.
4.5. Operating Cost – It is the operational cost of running the business. It includes employee expenses, branch related fixed and variable costs, operations cost, sales and marketing expenses etc.
4.6. Expected ROE: This is the return expected by shareholders of the company.
4.7. The final lending rate will be arrived at after adjusting for spread. Below factors are taken into consideration while determining the spread
4.8. Annualized Rate: The Company will communicate annualised rate of interest to all its borrowers so that its borrowers are aware of exact rates that will be charged to respective loan facility. The interest could be charged on monthly or quarterly rates for different products / segments.
4.9. The interest could be charged on daily, weekly, biweekly, monthly or quarterly rates for different products / segments.
4.10. Besides normal interest, the Company may levy additional / penal charges for noncompliance of material terms and conditions of loan contract by the borrower. These additional or penal charges for different products or facilities would be decided by the respective business / product heads. The penal charges shall not be capitalized i.e., no further interest computed on such charges.
4.11. Product wise Interest Rates – as per Annexure 1
4.12. Prepayment charges - The Company will ensure compliance with the regulatory requirements while charging pre-payment penalty for early closure of any of the loans. This will be documented clearly.
4.13. Processing/ Documentation and other Charges
Besides interest, other financial charges like processing fees, origination fees, cheque bouncing charges, late payment charges, re-scheduling charges, pre-payment / foreclosure charges, part disbursement charges, cheque swap charges, security swap charges, charges for issue of statement account etc., would be levied by the company wherever considered necessary. Besides these charges, stamp duty, service tax and other cess would be collected at applicable rates from time to time as communicated in the documentation provided. Any revision in these charges would have a prospective effect and will be communicated with the borrower. While deciding the charges, the practices followed by the competitors in the market would also be taken into consideration. Claims for refund or waiver of charges / penal charge / additional interest would normally not be entertained by the company and it is at the sole discretion of the company to deal with such requests.
5. Penal Charges
5.1. Penalty, if charged, for non-compliance of material terms and conditions of loan contract by the borrower shall be treated as ‘penal charges’ and shall not be levied in the form of ‘penal interest’ that is added to the rate of interest charged on the advances. There shall be no capitalisation of penal charges i.e., no further interest computed on such charges. However, this will not affect the normal procedures for compounding of interest in the loan account.
5.2. The Company shall not introduce any additional component to the rate of interest and ensure compliance to these guidelines in both letter and spirit.
5.3. The Company shall comply with this Board approved policy on penal charges or similar charges on loans, by whatever name called.
5.4. The quantum of penal charges shall be reasonable and commensurate with the non-compliance of material terms and conditions of loan contract without being discriminatory within a particular loan/product category.
5.5. The penal charges in case of loans sanctioned to ‘individual borrowers, for purposes other than business’, shall not be higher than the penal charges to non-individual borrowers for similar non-compliance of material terms and conditions.
5.6. The quantum and reason for penal charges shall be clearly disclosed by NBFCs to the customers in the loan agreement and most important terms & conditions/Key Fact Statement (KFS) as, in addition to being displayed on websites of NBFCs under Interest rates and Service Charges.
5.7. Whenever reminders for non-compliance of material terms and conditions of loan are sent to borrowers, the penal charges shall be communicated. Further, any instance of levy of penal charges and the reason therefor shall also be communicated.
5.8. The Customer shall be able to raise and the company will address any grievances relating to the penal charges in line with the Grievance Redressal Policy and Fair Practice Code.
6. Disclosure and Transparency
6.1. The loan amount, annualized rate of interest, tenure, amount of equated monthly installments shall be disclosed at the time of sanction of the loan.
6.2. The quantum and reason for penal charges shall be disclosed in the loan agreement in bold and terms & conditions / Key Fact Statement (KFS) as applicable, in addition to being displayed on the company website under Interest rates and Service Charges.
6.3. The quantum and levy of penal charges shall be communicated to the borrowers along with the reminders for non-compliance of material terms and conditions of loan are sent to borrowers.
7. Reset of floating interest rate on Equated Monthly Instalments (EMI) based personal loans
7.1. If at any time the Company provides EMI based floating rate personal loans, the Company at the time of the sanction of such loan shall take into account the repayment capacity of borrowers to ensure that adequate headroom/margin is available for elongation of tenor and/or increase in EMI, in the scenario of possible increase in the external benchmark rate during the tenor of the loan. However, in respect of EMI based floating rate personal loans, in the wake of rising interest rates, since customer grievances can arise related to elongation of loan tenor and/or increase in EMI amount, without proper communication with and/or consent of the borrowers. The Company is therefore required to put in place an appropriate policy framework. Towards this:
Annexure 1: Interest Rate Model
The Company shall be pricing the loans to the borrower keeping in view the RBI Guidelines relating to regulation of excessive interest charged by NBFCs. The rates of interest are decided based on the following factors.
| Sr No | Product | ROI Reducing |
|---|---|---|
| 1 | Personal Loan | Upto 45% |
| 2 | Unsecured Business Loan | Upto 45% |
Risk Based pricing Policy
The Company will enable as per its business plans, categorization of the borrowers into different risk buckets (A to E) based on several factors such as customer’s industry sector, geography location, bank statement analysis, business turnover, overall customer credit score and business profile, etc.. Based on the risk grade ROI will be charged to the customer.
Risk Grades are -
Penal Charges -
| Sr No | Product | Penal Charges |
|---|---|---|
| 1 | Personal Loan | Upto 36% Per Annum on Principal outstanding |
| 2 | Unsecured Business Loan | Upto 36% Per Annum on Principal outstanding |
Spicebulls Investments Ltd.
Fair Practices Code
1. Introduction
The purpose of this document is to define the framework for the fair practice code (the “Code”) for Spicebulls Investments Ltd (the “Company”).
The Reserve Bank of India’s (the “RBI”) “Master Circular- Fair Practice Code” issued vide its Notification No. DNBR (PD) CC.No.054/03.10.119/2015-16 dated July 01, 2015 and The Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023 has been referred to formulate this Code. The terms in this Code are defined as per the RBI’s various directions, guidelines issued and from time to time and, or as defined herein below. The Code shall be available on the Company’s website.
2. Objective
The objective of this Code is to:
The Code shall be applicable to all the categories of products and services offered by the Company and also apply to our related operations such as customer sourcing, loan processing, loan servicing and collection activities.
This Code has been framed by the Company and duly approved by its Board of Directors (the “Board”) and shall be reviewed or modified from time to time as per the applicable directions/guidelines of the RBI.
3. Applications for loans and their processing
3.1. All communications to the borrower shall be in vernacular language or in a language as understood by the borrower.
3.2. Loan application forms shall include all necessary information which affects the interest of the borrower. All necessary information that may be required by the borrowers with regard to the financial facility that is being applied for is available in the relevant loan application form.
3.3. The loan application forms shall also include necessary information which may affect the interest of the borrower, so that a meaningful comparison with the terms and conditions offered by other NBFCs can be made and informed decision can be taken by the borrower. The requisite documents required to be submitted along with the loan application shall be given on the website of the Company.
3.4. The Company shall give an acknowledgement for receipt of all loan applications which would also indicate the normal time frame within which loan applications complete in all respects shall be disposed of. For evaluating the loan application, the Company has laid out eligibility criteria as part of its Loan Policy. The Company will ensure that there is proper assessment of credit application made by the borrowers. The assessment will be in line with the Company’s credit policies and procedures. In case the proposal is not approved by the competent authority, the borrower shall be intimated accordingly.
3.5. Further, the Company shall make reasonable efforts to determine the true identity and beneficial ownership of the borrowers, the nature of customer’s business, reasonableness of operations in the account in relation to the customer’s business, etc. which in turn helps the Company to manage their risks prudently.
4. Loan appraisal and terms/ conditions
4.1. The borrowers shall be conveyed in writing, by means of a sanction/ offer letter or otherwise in vernacular language or language as understood by the borrower, the amount of loan sanctioned along with all the terms and conditions thereof including the annualized rate of interest thereon and method of application thereof, and the borrower shall, in turn, accept in writing the aforesaid terms and conditions, and the said acceptance shall be kept on record by the Company.
4.2. The loan agreement shall contain, the details of penal interest charged for loan repayment. All the borrowers shall be provided with a copy of the loan agreement along with all enclosures referred to in the loan agreement, in vernacular language or language as understood by the borrowers at the time of sanction/ disbursement of loan.
5. Penal Charges in Loan Accounts
5.1. Penalty for non-compliance of material terms and conditions of loan contract by the borrower shall be treated as ‘penal charges’ and shall not be levied in the form of ‘penal interest’ that is added to the rate of interest charged on the advances. The Company shall not capitalize penal charges i.e. no further interest computed on such charges.
5.2. The Company shall not introduce any additional component to the rate of interest.
5.3. The Company shall keep the quantum of penal charges commentating with the non-compliance of material terms and conditions of loan contract without being discriminatory within a particular loan / product category.
5.4. The penal charges in case of loans sanctioned to ‘individual borrowers, for purposes other than business’, shall not be higher than the penal charges applicable to non-individual borrowers for similar non-compliance of material terms and conditions.
5.5. The quantum and reason for penal charges shall be clearly disclosed by the Company in the loan agreement and most important terms & conditions / Key Fact Statement (KFS) as applicable, and on its website under Interest rates and Service Charges.
5.6. Whenever reminders for non-compliance of material terms and conditions of loan are sent to borrowers, the applicable penal charges shall be communicated. Further, any instance of levy of penal charges and the reason therefor shall also be communicated.
6. Disbursement of loans including changes in the terms and conditions
6.1. The Company shall ensure timely disbursement of loans sanctioned in conformity with the terms and conditions governing such sanction.
6.2. The borrowers shall be given an advance notice in vernacular language or language as understood by the borrower as to any change in the terms and conditions including disbursement schedule, interest rates, service charges, prepayment charges, etc. The said changes in interest rates and charges shall be with prospective effect and a clause in this regard shall be incorporated in the loan agreement.
6.3. The Company shall carry out post-disbursement supervision in accordance with normal business practice, the terms of sanction, and the guidelines issued by the Reserve Bank of India from time to time.
6.4. The Company shall carry out the decision to recall/ accelerate payment or performance under the agreement shall be in consonance with the loan agreement.
6.5. The Company shall release all securities on repayment of all dues or on realization of the outstanding amount of loan subject to any legitimate right or lien for any other claim the Company may be having against the said borrower. In case such, right of set-off is to be exercised and the Company shall give notice to the borrower about the same with full particulars about the remaining claims and the conditions under which the Company is entitled to retain the securities till the relevant claim is settled/ paid.
7. General terms
7.1. The Company shall not cause interference in the affairs of the borrower except for the purposes provided in the terms and conditions of the loan agreement and unless new information, not earlier disclosed by the borrower, has come to the notice of the Company.
7.2. In case of receipt by the Company of a request from the borrower for transfer of borrower account, the consent or otherwise, i.e., the objection of the Company, if any, shall be conveyed to the borrower within 21 (twenty-one) days from the date of receipt of such request, and such transfer, if consented to, shall be as per transparent contractual terms in consonance with law. However, in case where legal due diligence is required then the aforesaid time limit may get extended accordingly.
7.3. The Company shall not discriminate on grounds of sex, caste, and religion in the matter of lending. However, this does not preclude the Company from participating in credit-linked schemes framed for weaker sections of society.
7.4. In the matter of recovery of loans, the Company shall adopt legally valid processes and not resort to undue harassment, viz. persistently bothering the borrowers at odd hours, use of muscle power for recovery of loans, etc. The Company shall ensure that its staff is adequately trained to deal with the customers in an appropriate manner.
7.5. As part of making the evaluation process more effective, the Company may seek consent from the prospective borrower and its directors/ promoters for obtaining credit opinion from Experian (Experian Credit Information Company of India Private Limited) or any other credit rating agency or Banks/ FIs/ NBFCs.
7.6. The Company will ensure not to discriminate in extending products and facilities including loan facilities to physically/visually challenged applicants on the grounds of disability. All branches of the Company will render all possible assistance to such persons for availing of the various business facilities offered by the Company.
7.7. All personally identifiable information or other sensitive personal data of the borrowers shall be handled by the Company in accordance with the requirements of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 issued under the Information Technology Act, 2000 and the Digital Personal Data Protection Act, 2023 and the rules framed thereunder, as amended from time to time.
8. Applicant with Disability(ies)
The Company shall not discriminate in extending products and facilities including loan facilities to the physically / visually challenged applicants on the grounds of disability. They shall be treated at par with the other applicants and their application shall be dealt on merit as per the credit process and policy of the Company. All possible assistance will be provided to the applicants with the disability (ies) to enable them to understand, select and avail appropriate product or loan facility.
9. Responsibility of the Board of Directors
9.1. A grievance redressal mechanism is to laid down by the Company to address and deal with all the customer-related complaints. The mechanism ensures that all disputes arising out of the decisions of the functionaries of the Company are heard and disposed of at least at the next level.
9.2. The compliance of the Code and the functioning of the grievances redressal mechanism at various levels of management shall be periodically (quarterly) reviewed at various levels of management and a consolidated report of such reviews shall be submitted to the Board on half-yearly basis.
10. Grievance Redressal Officer (GRO)
10.1. The grievances of the borrowers shall be addressed directly to the GRO which is to be disposed of within a maximum period of 30 (thirty) days from the receipt of the grievance. The grievance redressal mechanism is further elaborated in the grievance redressal policy of the Company.
10.2. The name and contact details of the GRO of the Company are as under:
Name: Mr. Sanatan Malik
Designation: Nodal Officer
Address: JA - 122, 1st Floor, DLF Tower-A, Jasola District Center, Delhi- 110025
E-mail ID: nodal@spicebulls.com
10.3. If the complaint / grievance is not redressed within a period of one month, or / and the complainant is not satisfied with the reply, the borrower / customer / complainant may appeal to the Ombudsman, Reserve Bank of India at https://cms.rbi.org.in :- as per the RBI Integrated Ombudsman scheme vide Ref CEPD. PRD. No.S873/13.01.001/2021-22 dated November 12, 2021).
10.4. The public notice shall be served for the purpose of highlighting to the borrowers, the grievance redressal mechanism followed by the Company, together with details of the Nodal Officer and of the Regional Office of the RBI.
11. Regulation of Rate of Interest
11.1. The Board of Directors has adopted an interest rate model, as defined in its Interest Policy, for determining the rate of interest to be charged on loans and advances, processing and other charges taking into account relevant factors such as, cost of funds, margin and risk premium, etc. The rate of interest and the approach for gradations of risk and rationale for charging different rate of interest to different categories of borrowers shall be disclosed to the borrower or customer in the application form and communicated explicitly in the sanction letter.
11.2. The rates of interest and the approach for gradation of risks shall also be made available on the web-site of the companies. The information published on the website or otherwise published shall be updated whenever there is a change in the rates of interest. The rate of interest shall be annualized rate so that the borrower is aware of the exact rates that would be charged to the account.
Spicebulls Investments Limited
Grievance Redressal Policy
1. Introduction
Spicebulls Investments Ltd (the “Company”) is a customer centric origination and aims towards maintaining its business ethics, values and provide customer services to its customers. The process of handling customer grievances and complaints has been outline in this policy titled as the Grievance Redressal Mechanism (the “Policy”). The Policy is formulated in accordance with the Reserve Bank of India’s (the “RBI”) various directions, guidelines as issued from time to time.
2. Objectives of The Policy
Customer complaints constitute an important voice of the customer, and this Policy details the complaint handling through a structured grievance redressal framework. Complaint redressal is supported by a review mechanism, to minimize the recurrence of similar issues in future. The Policy follows the following principles:
3. Grievance Redressal Officer
The Board of Directors of the Company have appointed a Grievance Redressal Officer cum Nodal Officer (“GRO/NO”), who shall be responsible for overall functioning of this Grievance Redressal Mechanism of the Company. The GRO/NO shall also be responsible to address grievances escalated to him / her and for ensuring prompt and efficient functioning of this Policy.
4. Grievance Redressal Mechanism
The Company has a structured approach towards dealing with its customers’ grievances and complaints. Customer delight is our top priority, and we are committed to providing our customers with best-in-class experience. The following steps are available for a customer to register its complaint with the Company for its speedy redressal.
Step 1: Filling a Complaint
The Customer can contact the customer care on toll free number - +918796111660 at any time between 9:30 AM to 6 PM on all working days (Monday to Saturday). The Customer can also write to us at care@spicebulls.com. All complaints shall be duly acknowledged by the Company. The Company shall attempt to resolve the customer complaints within 15 (fifteen) days of receipt of such complaint.
Step 2: Escalation to Grievance Redressal Officer/Nodal Officer (GRO/NO)
In the event the grievance is not resolved with the defined time, or if the customer is not satisfied with response received, the customer can escalate his grievance to the GRO/NO at any time between 9:30 AM to 6 PM on all working days (Monday to Saturday) at +918796111660 or write to GRO/NO at nodal@spicebulls.com.
The GRO/NO shall endeavor to resolve the grievance within a period of 30 (thirty) days from the date of receipt of a grievance.
Details of GRO/NO:
Kind Attention: Mr. Sanatan Malik
Company: Spicebulls Investments Limited
Address: JA - 122, 1st Floor, DLF Tower-A, Jasola District Center, Delhi- 110025
Email: nodal@spicebulls.com
Step 3: Approach to Officer-in-charge of the Regional Office of Department of Supervision, Reserve Bank of India
In the event no response is received from GRO/NO within 30 (thirty) days from the date of registration of such grievance, the customer can appeal to the Officer-in-charge of the Regional Office of Department of Supervision, Reserve Bank of India at CMS - https://cms.rbi.org.in/
Address:
Centralised Receipt and Processing Centre,
4th Floor, Reserve Bank of India,
Sector -17, Central Vista,
Chandigarh - 160017, India
5. Resolution Process
On receipt of the customer complaint, the Company shall, send an acknowledgement to the complainant within 48 hours. All the communications between the Company and the customer related to the complaints shall be stored by the Company.
6. Review of Grievance Redressal Policy
The Company generates periodical MIS on the customer complaints and a consolidated report is placed before the senior management team of the Company comprising of the business head, CFO and the legal head, in quarterly intervals for their review and further instructions, if any.
Collection Partner Name
