Privacy Policy
CashBazar mobile
application ("App") is owned and operated by Bluesky Financial
Services Limited ("BFS", "us", "we" or
"our"), a company incorporated under the Companies Act, 2017 and
licensed as a Non-Banking Finance Company under License No.
SECP/LRD/92/BFSL/2022-87.
This Privacy
Policy ("Policy") is published in accordance with the directives of
the Securities and Exchange Commission of Pakistan (SECP), which require the
publication of a privacy policy governing the collection, use, handling, and
processing of personal information, including sensitive personal data or
information, in compliance with the applicable laws of Pakistan.
By using CashBazar
and availing the services provided by us or dealing with sensitive personal
information, you consent to the use and disclosure of your personal information
in accordance with this Policy. This Policy is incorporated into and subject to
the terms of use of the App.
For the purpose of
this Policy, the users of the services may be customers ("you" or
"your"), or any other person using our services or accessing our App
or website. Please review the full policy before using the App. If you do not
agree to this Policy or any part of it, please do not use or access the App,
our services, or our website.
1. INFORMATION
COLLECTION AND USE
We collect several
different types of your information for various purposes to provide and improve
the App. Our primary goal in doing so is to provide you a safe, efficient,
smooth and customized experience and services. In general, you can browse the
website or the App without telling us who you are or revealing any personal
information about yourself. However, to create an account on the website or the
App, you must provide us with certain personally identifiable information (PII)
that can be used to contact or identify you.
The information
may include, but is not limited to:
1.1 Personally
identifiable information
• Full name;
• Residential address;
• Work address;
• Marital status;
• Educational details;
• Mobile number;
• CNIC number;
• Employment information;
• Age;
• Gender;
• Emergency contacts (manually entered by
you);
• Live Selfie (for liveness detection and
KYC);
• Bank account information;
• Password and other registration
information;
Where possible, we
indicate the mandatory and the optional fields. You always have the option not
to provide your personal information by choosing not to use a particular
service or feature on our App or website. After registration, we may collect
additional personal data, which will be clearly displayed. While you can choose
not to provide this information, doing so may affect your credit assessment and
result in loan rejection.
1.2 Other
necessary information
1.2.1 Loan
Eligibility:Information to determine the User’s eligibility to
obtain a loan, such as credit history reports (obtained from authorized credit
bureaus with your consent), income particulars, wealth declarations, asset and
liability statements, details of various credit facilities you have procured from
other financial institutions, and any other information deemed necessary by us.
1.2.2 KYC
Compliance:Information relating to Know Your Customer (KYC) such as a copy
of your national identity card or passport, a photograph of you, and any other
information deemed necessary by the regulatory authorities in Pakistan for KYC
purposes.
1.2.3 Support
Communications:Records of communications made to our Customer Support
channels (e.g., calls to our helpline, emails). Note: We do NOT access your
device's Call Log or SMS/Text Message inbox.
1.3 We may collect
the following information after obtaining your explicit consent:
(1) Device
information (2) Location (3) Camera (4) Predefined specific applications (5)
Emergency contacts
1.3.1 Device
information
The
data/information the App collects, and how such data/information is used,
depends on how you manage your privacy controls on your device. We collect
information from the device when you download and install the App and
explicitly seek permission from you to get the required information from the
device. The information we collect from your device includes advertising ID,
unique device identifiers such as Android ID, information on operating system,
SDK version and mobile network information including carrier name, SIM Slot,
and Wi-Fi network information. We collect this information about your device to
provide automatic updates and additional security so that your account is not
used on/through other people's devices. In addition, this data provides valuable
insights to verify your device identity and analyze device behavior, thereby
allowing us to improve our services and provide an enhanced customized user
experience to you.
1.3.2 Location
When you use our
App, we may collect and analyze your approximate location information (Coarse
Location) to verify your service eligibility and ensure you are located within
Pakistan. We do not collect or track your precise (Fine) location. Our
application does not request the ACCESS_FINE_LOCATION permission from your
device. This collection occurs only while the App is actively in use in the
foreground. We strive to stop collecting location data when the App is not
running. You can disable geolocation tracking on your device at any time. We do
not share your location data with third parties, except as allowed under the
exceptions stated in this Policy.
1.3.3 Camera
CashBazar may
request camera access to scan the required Know Your Customer (KYC) documents.
After the picture is taken, CashBazar will fill relevant fields automatically,
minimizing manual entry errors and saving you time. Besides that, the camera
will also be used to conduct your Video KYC process (Live Selfie). The data
will be transferred and uploaded over a secure connection
(https://cash-bazar.com/). All Data will be stored within Pakistan on local
cloud servers provided by Cyber Internet Services Pvt. Ltd.
1.3.4 PREDEFINED SPECIFIC APPLICATION CHECKS
To ensure
service security, prevent fraud, and meet regulatory requirements for
responsible lending, CashBazar conducts limited, on-device checks for a
predefined and static list of applications. This list is strictly limited to
finance-related applications and potential high-risk utility software
(e.g., location spoofers, multi-account emulators).
Data
Minimization & Privacy by Design: We strictly adhere to data minimization
principles. We do not request or utilize the QUERY_ALL_PACKAGES permission,
meaning we cannot and do not access your entire installed application
inventory. Furthermore, we do not transmit actual application names or package
names to our servers. Instead, detection results are converted into predefined,
pseudonymized security codes on your device before transmission.
Purpose of
Collection: The
collection of these specific security codes is strictly limited to core risk
management functionalities: anti-fraud verification, securing your account, and
identifying malicious "loan stacking" abuse to comply with the
guidelines set forth by the Securities and Exchange Commission of Pakistan
(SECP).
1.3.5 EMERGENCY
CONTACTS
With your consent,
we will collect information on two of your emergency contacts for identity
verification, risk management, anti-fraud controls. We will only collect this
information through your manual data entry of the emergency contact's
details, including your relationship to them, their phone numbers, and names.
We will upload this contact information in encrypted format to our servers in a
secure network environment.
2. USE OF YOUR
INFORMATION
We use the
information you provide to:
• Verify your identity;
• Deliver and improve our services,
including credit profiling for loan facilitation;
• Offer customized products through
third-party partners;
• Analyze usage, diagnose issues, and
maintain security;
• Send notifications and respond to your
queries;
• Manage our relationship and suggest
relevant services;
• Comply with legal and regulatory
requirements;
• Conduct identity checks for our lending
partners;
• Improve our products and services through
data analysis;
• Enable access to services from our
partners as permitted by law.
We retain your
information as long as necessary to provide services, comply with legal
obligations, resolve disputes, and enforce agreements.
3. USE AND
DISCLOSURE OF YOUR PERSONAL AND OTHER INFORMATION
We collect, store,
and use your personal information to provide and improve our services,
customize your experience, and develop new features. If we intend to use your
data for marketing, you will have the option to opt out.
We may also use
your information to:
• Resolve disputes and troubleshoot issues;
• Ensure platform safety;
• Conduct analytics and measure
satisfaction;
• Inform you of relevant offers and updates;
• Detect and prevent fraud or illegal
activity;
• Enforce our terms and improve services.
We also analyze
user activity and demographics to enhance our offerings.
4. DATA
SECURITY
All CashBazar
transactions are protected by 256-bit SSL encryption and transmitted over a
secure HTTPS connection (https://cash-bazar.com/). Data is stored locally on a
Pakistan-based cloud server provided by Cyber Internet Services (Pvt.) Ltd.
5. DISCLOSURE
TO THIRD PARTIES
We may also share
your information with regulated third parties with your consent, or as
disclosed at the time you provide us with information. We also reserve the
right to disclose and transfer your information if we go through a business
transition, such as a merger, acquisition by another company, sale of all or a
portion of its assets, or other corporate change, including during any due
diligence process.
• With Service Providers: When you provide
information through the App, we may share it with service providers who help
develop, host, maintain the App, offer customer support, send communications,
assist with marketing, or provide analytics. These providers are only
authorized to use your information to perform services for us or comply with
the law.
• Sharing for Legal Purposes: We may
disclose your information to comply with legal requirements, law enforcement,
prevent harm or fraud, protect our rights or property, or defend against legal
claims.
• With Credit Bureaus and Data Partners: We
may share your information with licensed credit bureaus and approved data
providers to perform credit profiling, risk assessment, and related financial
evaluations, as required for loan processing and regulatory compliance.
• With Technology Partners: We may also
share your information with authorized technology partners for secure user
verification, KYC compliance, and to track your interactions with the App.
These partners operate under strict confidentiality agreements and may use your
information only to support the services we provide or as permitted by law.
All third-party
data sharing is governed by strict confidentiality agreements and limited to
the purposes stated in this Policy. No unauthorized use or disclosure will
occur. By using our services, you consent to this data sharing. Any new use of
your data will require your explicit consent, as per SECP regulations.
6. CHANGES IN
THIS POLICY
We may add to,
delete, or change the terms of this Policy from time to time by uploading an
amended Policy on this App or website. Your continued use of the App or any
online service following the upload will constitute your agreement to the
revised Policy.
7. ACCESSING
YOUR INFORMATION
At any point in
time, users can choose to edit or delete any personal information shared for
use of the App or website. However, deleting key data may affect your access to
certain services. For any changes, supporting documents may be required for
verification.
8. YOUR PRIVACY
CONTROLS
You have certain
choices regarding the data we collect and how it is used:
•Device-level settings: Your device may have
controls that determine what information we collect. For example, you can
modify permissions on your Android device for access to camera permissions.
• Delete your App account with
personal information.
•Contact our Grievance Officer to remove
specific content or data. To request deletion of your account and personal
data, please visit: https://cash-bazar.com/.
9. SECURITY
PRECAUTIONS
We implement
physical, administrative, and technical safeguards to protect your information
from unauthorized access, including:
• SSL encryption for data transmission
• OTP verification and restricted access
controls
• Regular audits and compliance reviews
• Confidentiality agreements with all
personnel and third-party partners
• Secure data storage on Pakistan-based
servers, per legal standards
We continuously
monitor and improve our systems to guard against data breaches and cyber
threats.
10. LINKS TO
OTHER SITES
CashBazar may link
to external websites. We are not responsible for their content or private
practices. Please review their privacy policies separately.
11. PROTECTION
OF MINORS
We place great
value on protection of personal information relating to minors. Any user under
the age of 18 is not authorized to use our services and we shall not be liable
for any unauthorized usage of our services.
12. YOUR
CONSENT
By using our
services, you consent to the collection, use, and storage of your data as
outlined in this Policy. Updates to this Policy will be posted on this page.
You may withdraw or limit your consent at any time, subject to the terms
herein.
13. CONTACT US
You can contact us
through the following ways:
App: CashBazar
Postal Address:
ISE Tower, Floor 6th, Blue Area, Islamabad, Pakistan
Customer Service
Email: customerservice@cash-bazar.com
Help Desk Number:
+92 3702770328
Business hours:
10:00 a.m. to 6:00 p.m.