TapStart Capital

Terms & Conditions
of Loan Facility

This document sets out the terms and conditions applicable to the Loan (defined below) provided by TapStart Capital Private Limited, a non-banking finance company registered with the Reserve Bank of India, and having its registered office at Unit No. G‑408, 4th Floor, Gamma Block, Varthur Hobli, Sigma Soft Tech Park, No. 7, Whitefield Road, Bangalore – 560066 (“TapStart” or “Lender”).

TapStart enables eligible persons (“you” or “Borrower”) who are approved and authenticated based on TapStart’s applicable prevailing internal policies and processes (collectively, “Policies”) to avail of a loan (“Loan”) through Freo’s online platform (“Platform”). The Lender reserves its right to refuse or reject any Application Form (defined below), notwithstanding the Applicant (defined below) satisfying the eligibility criteria, if any, set by the Lender for the sanction of the Loan. All customers using the Platform and availing the Loan are subject to terms and conditions set out herein below (collectively, “Terms and Conditions” or “T&Cs”).

You confirm that you have carefully read and fully understood all the terms and conditions that are listed herein and that following provisions shall be applicable to you in the capacity of a borrower.

Definitions and Reference Terms

1.1

“Application Form” means the application form as prescribed by the Lender from time to time and filled in by the Borrower/s to avail the Loan.

1.2

“Applicant/s” or “Borrower/s” or “Co‑Borrower/s” means any Person, whose Application Form either as Borrower or Co‑Borrower, has been processed according to the prescribed Eligibility Criteria and to whom the Loan has been sanctioned and/or disbursed by the Lender. The expressions namely “Applicant/s” or “Borrower/s” or “Co‑Borrower/s”, shall include his/her/their heirs, executors, administrators and legal representatives respectively.

1.3

“Approved Bank” means a designated bank approved by the Lender for the purposes related to the Loan.

1.4

“Annual Percentage Rate (APR)” means the annual cost of credit to the borrower which includes interest rate and all other charges associated with the credit facility.

1.5

“Co‑Borrower/s” means any Person named and described as Co‑Borrower in the Application Form and shall include his/her/their heirs, executors, administrators and legal representatives respectively.

1.6

“Cooling off/look‑up period” means the time window as determined by the Board of the Lender which shall be given to borrowers for exiting digital loans, in case a borrower decides not to continue with the loan.

1.7

“Delayed Payment Charges” shall mean the additional amount payable by the Borrower/s to the Lender on account of any delay in payment of any Instalment and intimated to the Borrower/s.

1.8

“Designated Bank Account” means the bank account of Borrower/s identified and designated as such by Borrower to Lender.

1.9

“Eligibility Criteria” means the minimum eligibility criteria set forth by the Lender to judge the credit worthiness of an Applicant/s, which is subject to change from time to time, at the sole and absolute discretion of the Lender.

1.10

“Fee” means the aggregate amount payable by the Borrower/s to the Lender, as per the details provided in the Application Form, towards the line set up fee, servicing fee, loan processing fee, the registration fee and such other details provided in the Application Form.

1.11

“Guarantor/s” means any Person named and described as a guarantor in the Application Form.

1.12

“Instalments” means the principal, Fee and interest therein payable at specific intervals, as per terms of the Loan Documents / repayment schedule during the tenor of the Loan, towards repayment of the Outstanding Balance.

1.13

“KYC” means the Know Your Customer Policy adopted by the Company (as may be amended from time to time by the Reserve Bank of India).

1.14

“Key Fact Statement” or “KFS” means a statement of key facts of a loan agreement, in simple and easier to understand language, provided to the borrower in a standardised format.

1.15

“Lender” means TapStart Capital Private Limited.

1.16

“Loan Documents” means these Terms and Conditions, any and all Application Form, Sanction Letter, account statements, Key Fact Statement including APR and all other documents, instruments, certificates, guarantees and agreements executed and/or delivered by the Borrower/s, Guarantor/s or any third party in connection with Loan in favour of the Lender as per terms of the Sanction Letter.

1.17

“Outstanding Balance” means the balance of the Loan outstanding along with all amounts payable by the Borrower/s to the Lender including principal amount, interest, costs, Fee, charges, expenses, etc.

1.18

“Payment” means the payment towards instalments or charges, i.e., principal, interest, Fee, default interest or charges in respect of the Loan through any mode as approved by the Lender.

1.19

“Person” shall mean any individual, corporation, partnership, company under the purview of Companies Act, 2013, trust, unincorporated organization, Hindu undivided family or any Governmental Authority or political subdivision thereof.

1.20

“Pre‑Payment” means the payment of the entire Loan including the Rate of Interest, Fee, and other charges, according to the procedure prescribed in Para 7 of these T&Cs, through any mode as approved by the Lender.

1.21

“Rate of Interest” or “Interest” means the rate at which interest on the Loan is payable by the Borrower/s and/or the Guarantor to the Lender and mentioned in the Application Form/Sanction Letter, as amended from time to time with prior intimation to the Borrower/s.

1.22

“Recall” means at any time during the currency of the Loan, TapStart shall have the sole and exclusive right to cancel the Loan, with or without reasons, and declare all obligations of Borrower immediately due and payable.

1.23

“Receipt” means the receipt issued by the Borrower in favour of the Lender in the form prescribed by the Lender for acknowledgment of disbursal of the Loan or a part thereof.

1.24

“Repayment Instruments” means Post Dated Cheques (PDC), Electronic Clearance Service (ECS) and/or National Automated Clearing House Mandate (NACH) or Standing Instructions (SI) or any other means for the debit clearing service as notified by the Reserve Bank of India or National Payment Corporation from time to time.

1.25

“Sanction Letter” means the letter issued by the Lender sanctioning the Loan along with the relevant particulars, terms & conditions mentioned in the same.

1.26

“Scheduled Due Date” means each of the dates on which the Instalments together with any other costs, charges, Fee, and expenses if any, are due and payable by the Borrower to the Lender.

1.27

“Standing Instructions” and/or “SI” means the written instructions issued by the Borrower/s to the Bank where the Borrower/s maintain/s an account, an amount equal to the Instalments, in favour of the Lender for repayment of the Loan.

General Terms of Use – Loan Facility

2.1

Privacy Policy: You agree and acknowledge that the availing of the Loan facility is contingent on your acceptance and continuous adherence with the T&Cs and other relevant documentation published on the Platform and/or otherwise made available to you, including TapStart’s privacy policy (“Privacy Policy”) which may be updated from time to time.

2.2

Eligibility: You represent and warrant that you are competent and eligible to enter into a legally binding agreement and be bound by these T&Cs. You represent and warrant that all particulars, information and details given in the application form are true, correct and accurate and you have not withheld/suppressed any material and relevant information from Lender.

2.3

Credit Limit: You understand and agree that: (a) the limits applicable to the Loan facility are subject to TapStart’s sole discretion and internal criteria; (b) TapStart may at its sole discretion reduce or Recall the Loan facility at any time, with prior intimation and without assigning any reason therefor.

2.4

Loan Facility: Your application for the Loan facility shall be processed as per the Policies. Upon a valid disbursement request made by you through the Platform, the loan amount shall be disbursed to your Designated Bank Account. Every instance of Disbursement Request shall be treated as a separate loan identification number issued on the respective date of actual disbursement.

2.5

Terms of Disbursement and Draw-downs: Subject to the terms and conditions set forth herein, the Lender may extend the Loan to the Borrower up to an aggregate of the principal amount as specified in the Loan Sanction Letter. The Borrower shall utilize the Loan only for the specific purpose as stated in the Loan Documents.

2.6

Rate of Interest: The rate of interest will depend on the risk gradation of the customer. The Lender shall be entitled to revise the Rate of Interest at any time as per its policy and/or applicable laws and regulations during the tenor of the Loan at its discretion. The Lender shall inform the Borrower/s about the variation in the Rate of Interest in due course.

2.7

Direct and Indirect Taxes and Duties: The Borrower shall pay to the Lender any and all taxes, duties or cesses including but not limited to service tax, stamp duty, VAT, duties, and/or all other levies and imposts payable in relation to the Loan provided by the Lender.

Payments

3.1

Repayment of a loan amount will be through instalments/EMIs comprising of principal and/or interest, on a monthly basis on the Scheduled Due Date, from the first due date to the last due date as mentioned in the Application Form/Sanction Letter/Loan Documents, time being the essence of the contract, by issuing Repayment Instrument to the Lender.

3.2

The Borrower/s shall not instruct the Lender to withhold depositing the Repayment Instrument. Any non-presentation/delayed presentation of the Repayment Instrument, due to any reason, will not affect the liability of the Borrower/s to pay the Instalments on time.

3.3

The Lender shall be authorized to present the appropriate Repayment Instrument in respect of the Instalments at any time on or after the due date. In the event the Lender does not deposit the Repayment Instrument before the expiry of its validity, the Borrower/s shall deliver a new Repayment Instrument of a like amount within 7 (seven) days of a request by the Lender.

3.4

If the Borrower/s wish to swap the Repayment Instrument issued, the Borrower/s may do so on paying swap charges stipulated in the Sanction Letter and/or Loan Documents. Any costs, including applicable taxes, incurred in this regard shall be borne by the Borrower/s.

3.5

The Borrower/s shall not dispute the Lender’s method of calculating Instalments.

3.6

The Borrower/s shall be liable to pay dishonour/bounce charges for each Repayment Instrument bounce. In addition, the Borrower/s shall be liable for Delayed Payment Charges on the outstanding amount from the due dates of the Instalments till the date of receipt and/or realization of payment.

3.7

If any Repayment Instrument bounces and the Borrower/s issue/s another in lieu, the Lender shall have the right to retain the bounced Repayment Instrument in its record and/or destroy the same as the Lender may deem fit and proper.

3.8

In the event of foreclosure or closure of the Loan, the Lender shall return the Repayment Instrument, if any, lying with the Lender to the Borrower/s within 30 days from the date when the Lender receives the request from the Borrower/s.

3.9

The Loan shall be repayable by the Borrower/s on demand by the Lender. Notwithstanding specifying a repayment schedule, the Lender shall have the right to be paid on demand the entire Loan along with other dues.

3.10

The Lender shall have the first lien on the Borrower/s emoluments and terminal dues from the employer/s. In case the Borrower/s defaults on the Loan, the Lender shall have the first right to collect the entire termination value of the Loan from the amount due to the Borrower/s by the employer/s.

3.11

The Lender would at its discretion be free to Recall the entire Loan, if any information supplied by the Borrower/s regarding income, employment, personal details, or any other information are found to be incorrect or false for any reason whatsoever.

3.12

The Borrower/s and/or the Guarantors shall be jointly and severally liable to the Lender for repayment of the Loan including the Rate of Interest, any other costs, charges, Fee, and expenses.

Other Conditions

4.1

The Borrower shall comply with the following requirements:

(a)Intimate the Lender immediately of any change in the residential/office address, as well as any change in the bank account through which the Borrower/s has/have issued the Repayment Instrument;
(b)Continue to allow salary and/or business proceeds to be deposited in the Designated Bank Account from which Repayment Instruments have been issued to the Lender;
(c)The Borrower/s shall forthwith intimate any change of employment or status of employment and/or business or profession pursuant to which the Lender shall have the discretion to terminate these Terms and Conditions if it deems fit;
(d)The Borrower/s hereby authorizes the Lender to take possession and to sell any products purchased from the Loan proceeds to recover the Outstanding Balance including any interest, charges, etc.

Permitted Uses of the Loan Facility

5.1

The loan amount duly disbursed to you shall be used for the purposes stated in the Loan Documents. The Loan facility shall not be used for:

(a)Speculative and/or capital market use;
(b)Business end-use purpose;
(c)Prohibited/anti-social purposes;
(d)Gambling, lottery, races and activities speculative in nature; and/or
(e)Purchase of gold/gold bullions/gold coins/gold jewellery/gold exchange traded funds/gold mutual funds.

Delay in Repayment

6.1

If you fail to pay any amount payable to TapStart under a Loan Agreement, you will be liable for payment of default charges (“Penal Charges”) as mentioned in the Loan Agreement. Unless otherwise specified by TapStart:

(a)Interest shall accrue from the date of disbursement of the loan amount (or part thereof);
(b)Interest shall be computed on the basis of a year of 365 (three hundred sixty five) days and the actual number of days elapsed;
(c)Interest shall be computed on monthly intervals or on such periodic intervals as may be determined by TapStart from time to time; and
(d)In case of any payment default, interest shall be compounded every month on the overdue amount.

Pre-Payment

7.1

The prepayment of the loan shall be made and accepted as per Policies and rules of TapStart and in accordance with statutory guidelines. Foreclosure charges applicable on the loan availed will be as per TapStart’s prescribed rates as specified in the Sanction Letter and/or other documents, by giving to the Lender not less than 15 (fifteen) days prior notice in writing.

7.2

The Borrower shall pay the Lender the stipulated Instalments and other sums due up to the date of such prepayment and the principal outstanding calculated on a reducing balance basis at the Rate of Interest specified in the Sanction Letter and Loan Documents.

7.3

The Lender shall charge pre-payment charges (as notified to the Borrower/s at the time of availing Loan) and as amended from time to time on the principal outstanding.

7.4

The Lender would be at liberty to appropriate the amount so prepaid towards prepayment of charges, interest, additional interest, delayed payment charges, all other charges and fees payable under these Terms and Conditions and then towards the principal amount or in any other manner that the Lender may deem fit in its sole and absolute discretion.

Cooling Off / Look-Up Period

8.1

Borrower shall be given an explicit option to exit digital loan by paying the principal and the proportionate APR without any penalty during an initial “cooling off period”. The cooling off period shall be determined by the Board of TapStart and specified in the Loan Documents. For Borrowers continuing with the loan even after look-up period, pre-payment shall continue to be allowed as per Para 7 above.

Event of Default

9.1

On and at any time after the occurrence of an Event of Default, TapStart may, with or without any notice to you and with or without the intervention of a court, cancel/recall the Loan facility. In such event, your entire dues towards TapStart shall become immediately repayable/payable.

9.2

For the purposes hereof, an “Event of Default” shall mean any or all of the following:

9.2.1Non-payment of principal or interest by the relevant due date;

9.2.2Borrower’s usage of the Loan facility in contravention with the terms hereof;

9.2.3Any breach of the terms hereof or misrepresentation made by the Borrower in the loan application, KYC verification or any other document;

9.2.4If the repayment of any loan amount is refused for any reason whatsoever or if the Borrower withdraws or revokes the payment mandate;

9.2.5Any material information supplied by the Borrower/s is found to be untrue, false or incorrect;

9.2.6The Borrower/s has/have admitted in writing that they are unable to pay the debts and are willing to be adjudged bankrupt;

9.2.7If the Borrower/s commit any act of bankruptcy or makes assignment for the benefit of creditors;

9.2.8Business operations of the Borrower/s are suspended for more than three months;

9.2.9Carrying on of the Borrower’s business becomes illegal or contrary to any Law, Rules & Regulations;

9.2.10The Borrower/s, being an individual, has an insolvency notice served on him or is declared insane or is convicted of any offence;

9.2.11Any Repayment Instrument delivered by the Borrower/s is not encashed/acted upon or dishonoured for any reason whatsoever on presentation;

9.2.12Any instruction is given by the Borrower/s to stop payment on any Repayment Instrument;

9.2.13If the Borrower/s commits a default under any other agreement executed with the Lender or any of its affiliates or group companies; and

9.2.14If any other event has occurred which in the opinion of the Lender jeopardizes its interest or would make it difficult for the Lender to recover the Loan.

9.3

You understand that in the event of any fraudulent or suspicious transactions under the Loan facility, TapStart reserves the right to suspend/cancel the Loan or Credit Limit offered and take such actions as it deems fit under law.

9.4

Upon occurrence of any Event of Default, the Lender shall have the right to declare all sums outstanding immediately repayable and upon the Borrower failing to make the said payments within 7 (seven) days thereof, the Lender may at its sole discretion: (a) require the Borrower/s to pay liquidated damages; and (b) exercise any other right or remedy available under applicable law.

9.5

The Borrower/s shall also be liable for payment of all legal and other costs and expenses resulting from the defaults or the exercise of the Lender’s remedies.

Consent

10.1

Upon providing your consent, which will be obtained during the registration/application process, you understand that TapStart shall have the right to collect the credit rating information from any third party partners of TapStart in order to determine your eligibility and enhance your Loan or Credit Limit, if applicable.

10.2

TapStart may also take a one-time access for camera, microphone, location or any other facility necessary for the purpose of on-boarding/KYC requirements, with the explicit consent of the Borrowers.

10.3

If you provide this consent, you accept that such information will be accessed by TapStart for checking your eligibility for the Loan facility or for enhancing your credit limit. In the event that you withdraw your consent, TapStart will stop collection of such data but may continue to store the data and use it for internal purposes to further improve its services.

10.4

You hereby give your explicit consent to TapStart to search and download your records/documents/information available, if any, on Central KYC Registry (CKYCR). You agree that Lender may avail services from any third party to conduct Aadhaar based KYC authentication.

Links to Other Websites

11.1

The Platform may contain links to third party websites or portals that are not owned or controlled by TapStart or its affiliates. You expressly agree and acknowledge that TapStart does not have any control over, and assumes no responsibility for, the content, privacy policies, or practices of any such Third Party Websites. By using the Platform, you expressly relieve TapStart from any and all liability arising from your use of any Third Party Websites.

Intellectual Property

12.1

The wordmarks, logos and service marks (collectively, “Marks”) displayed on the Platform are the properties of TapStart. You are prohibited from using any Marks for any purpose without the express prior written permission of TapStart. All information and content including any software programs available on or through this Platform (collectively, “Contents”) are protected by copyright.

Assignment

13.1

The Borrower/s shall not be entitled to transfer or assign the Loan. The Borrower/s expressly recognize/s and accept/s that the Lender shall be absolutely entitled and shall have full power and authority in respect of the Loan to sell, assign or transfer in any manner, in whole or in part, any or all Outstanding Balance of the Borrower/s to any third party of the Lender’s choice without reference to or without written intimation to the Borrower/s.

13.2

The Borrower/s shall pay to the third party the difference between the amount of the Loan outstanding and the amount received by the Lender in the event of a transfer of the portfolio to a third party. The Borrower/s expressly recognize/s and accept/s that the Lender shall be absolutely entitled and have full powers to appoint one or more third parties and delegate to such third parties the right and authority to collect on behalf of the Lender all unpaid Instalments.

Compliance with the Regulations

14.1

The Borrower/s and the Lender agree to comply jointly and severally with all applicable laws and regulations from time to time in force including any amendments, modification or change thereof which may be attracted and the Borrower/s shall indemnify the Lender in respect of any loss, claim or expense as a result of non-compliance.

14.2

The amount of Instalments shall be increased by incremental taxes, whether sales, excise, security tax or interest’s tax and other related taxes now levied on this transaction or hereafter to be levied.

Further Assurances

15.1

The Borrower/s shall pay all costs and other expenses incurred by the Lender for enforcing the Terms and Conditions and/or for recovery of the Loan and all amount(s) payable to the Lender.

15.2

The Borrower/s and Guarantor/s undertake/s to indemnify and keep the Lender indemnified in respect of all statements, representations, warranties and undertaking made by the Borrower/s in the Application form, these Terms and Conditions and any other documents submitted.

15.3

The Borrower/s/Guarantor/s shall execute, deliver and perform such further acts or documents which the Lender may reasonably require to effectuate the purposes of these Terms and Conditions or any of the other Loan Documents.

Notice

16.1

Any notice/letter/other communication sent by the Lender to the Borrower and/or the Guarantor/s shall be sent at the latest address available in the records of the Lender and shall be deemed to have been delivered on expiry of 48 hours after it has been sent by registered post/courier/other modes of delivery. The Borrower/s shall immediately intimate the Lender of any change in the office/residential address.

Co-Borrower

17.1

The Co-Borrower shall be jointly and severally liable for the Borrower/s liability/obligation/responsibility under the Loan. The Co-Borrower’s obligations in relation to the Loan shall be concurrent with that of the Borrower/s in all respects as if the Co-Borrower was the Borrower and shall guarantee to the Lender regular and punctual payment of all instalments as well as pay the instalments and other dues in the event of default of the Borrower/s.

Guarantor/s

18.1

The Guarantor/s shall be jointly and severally liable with the Borrower/s under the Loan. The Guarantor/s obligations in relation to the Loan shall be concurrent with that of the Borrower/s in all respects as if the Guarantor/s was the Borrower/s, and accordingly, Guarantor/s shall guarantee and regularly and punctually pay to the Lender all Instalments as well as other dues payable under the Loan in the event of default by the Borrower/s.

Consent to Disclosure

19.1

The Borrower/s and Guarantor/s understand that as a pre-condition relating to grant of Loan, the Lender requires the consent of the Borrower/s and Guarantor/s for disclosure by the Lender of information and data relating to Borrower and Guarantors, of the Loan availed, obligations assumed and default if any committed.

19.2

Accordingly, the Borrower/s and Guarantor/s has/have no objection to the disclosure by the Lender of: (a) information and data relating to Borrower/s and/or Guarantors; (b) information or data relating to any credit facility availed/to be availed; (c) information and data relating to obligations assumed; and (d) information and data relating to default, if any, as the Lender may deem appropriate and necessary to disclose.

19.3

The Borrower/s and Guarantor/s declare/s that the information and data furnished by them to the Lender is true and correct.

19.4

The Borrower/s and the Guarantor/s undertake/s that the Credit Information Bureau (India) Limited and any other agency so authorized may use, process the said information and data disclosed by the Lender in the manner as deemed fit by them and may furnish for consideration the processed data to banks/financial institutions and other credit grantors or registered users.

Disclaimers

20.1

The Platform and the services rendered by TapStart are provided on an “as is” and “as available” basis. TapStart expressly disclaims all warranties of any kind as to the service and all information, Loans, and other content included in or accessible from the service, whether express or implied.

20.2

TapStart makes no warranty that: (a) the Platform will meet your requirements; (b) the service rendered will be uninterrupted, timely, secure, or error-free; (c) the results that may be obtained from the use of the service will be accurate or reliable; (d) the quality of any Loan facility will meet your expectations; and/or (e) any errors in the technology will be corrected.

Indemnity & Limitation of Liability

21.1

You agree to indemnify and hold TapStart and its officers, directors, agents, affiliates and personnel harmless from any and against any claims, causes of action, demands, recoveries, losses, damages, fines, penalties or other costs or expenses of any kind or nature arising out of or related to: (a) your breach of the undertakings, representations, warranties and covenants made under these Terms and Conditions; and (b) your violation of applicable law or the rights of a third party.

21.2

IN NO EVENT SHALL TAPSTART OR THE ENTITY OWNING OR HOSTING THE PLATFORM BE LIABLE TO YOU FOR ANY INDIRECT, INCIDENTAL, SPECIAL, PUNITIVE, OR CONSEQUENTIAL DAMAGES WHATSOEVER RESULTING FROM ANY (I) ERRORS, MISTAKES, OR INACCURACIES OF CONTENT, (II) PERSONAL INJURY OR PROPERTY DAMAGE OF ANY NATURE WHATSOEVER, RESULTING FROM YOUR ACCESS TO AND USE OF THE PLATFORM, (III) ANY UNAUTHORIZED ACCESS TO OR USE OF TAPSTART’S SECURE SERVERS AND/OR ANY AND ALL PERSONAL INFORMATION AND/OR FINANCIAL INFORMATION STORED THEREIN, (IV) ANY INTERRUPTION OR CESSATION OF TRANSMISSION TO OR FROM THE PLATFORM, (V) ANY BUGS, VIRUSES, TROJAN HORSES, OR THE LIKE, WHICH MAY BE TRANSMITTED TO OR THROUGH THE PLATFORM BY ANY THIRD PARTY. THE FOREGOING LIMITATION OF LIABILITY SHALL APPLY TO THE FULLEST EXTENT PERMITTED BY LAW.

Miscellaneous

22.1

Disclaimers: TapStart employs appropriate technical and organizational security measures at all times to protect the information it collects from you. However, no method of transmission over the internet, or method of electronic storage is fully secure. Accordingly, TapStart cannot guarantee its absolute security.

22.2

Right to deny: TapStart retains the right to, at its sole discretion, deny access to Loan facility, at any time and for any reason, including, but not limited to, for violation of the T&Cs and/or applicable law.

22.3

Interpretation: When a reference is made in these Terms and Conditions to a Para, Section, or Schedule, such reference shall be to a Para, Section or Schedule contained hereunder unless otherwise indicated.

22.4

Effective Date of Terms: These Terms and Conditions shall have become binding on the Borrower and the Lender on and from the date of the sanction/grant/disbursal of the Loan. It shall be in force till all the monies due and payable to the Lender are fully paid to the satisfaction of the Lender.

22.5

Representatives and Assigns: The Borrower, his/her/their heirs, legal representatives, executors, administrators, and successors shall be bound by all the covenants of these Terms and Conditions.

22.6

Non-Waiver: Any omission or delay on the part of the Lender, in exercising any of rights, powers or remedy accruing to the Lender upon failure by the Borrower, shall not be deemed to constitute a waiver by the Lender of any of its rights.

22.7

Confidentiality: The Lender shall exercise care while handling any confidential information. However, the Borrower/s acknowledges and accepts that the Lender shall be entitled to disclose information: (a) to the Lender’s affiliates; (b) to prospective transferees or purchasers of any interest in the Loan; (c) as required by law or any government order or direction; and (d) as deemed necessary by the Lender while exercising its remedies under the Loan Documents.

22.8

Costs and Expenses: The Borrower/s shall forthwith on demand, pay to the Lender, on a full indemnity basis, all costs and expenses (including legal costs) incurred and/or to be incurred by the Lender for the enforcement of these Terms and Conditions and realization/recovery of the amount of the Loan.

22.9

Amendments: These Terms and Conditions may be amended by the Lender at any time. Any such amendment shall take effect only prospectively. The Lender shall, upon such variation or amendment being made, inform the Borrower/s in respect of any variation or amendment in the Terms and Conditions.

22.10

Revoke the sanction: TapStart shall be entitled to revoke the sanction and to add, delete or modify all or any of the terms and conditions of the facility if there is any material change in the purpose(s) of the loan facility, if any information and/or statement given by the Borrower is found incorrect, incomplete, or misleading, or if there is a breach of the terms and conditions of the facility.

22.11

Governing Law & Jurisdiction: These T&Cs are governed by and shall be construed in accordance with the laws of India. The courts in Bangalore, India shall have exclusive jurisdiction with respect to any dispute that may arise out of or in connection with these T&Cs.

22.12

Refund Policy: If any Borrower makes an additional/extra/excess payment against any loan, he/she can contact us at hello@tapstart.com. The Company shall endeavor to reconcile the said excess payment in the loan account within 30 days of receipt. The excess amount, if any, after reconciliation, shall be refunded back to the source account of the borrower at the earliest.

22.13

Grievances: In case of any grievance, you may contact the grievance officer at:

Email: shaurya@tapstart.in

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TapStart Capital

Privacy Policy

Tapstart Capital Private Limited (hereinafter, “Tapstart” or “we”) maintains this website, i.e., www.tapstart.in (hereinafter, “Site”). By availing of any service / credit facility being provided by Tapstart directly or indirectly including by utilizing the Site (collectively, “Services”), you have agreed to each and all of the terms and conditions of this privacy policy (hereinafter, “Privacy Policy”) as set forth below and waive any right to claim ambiguity or error in the same.

This Privacy Policy seeks to help you understand:

The type of personal or sensitive personal data or information collected by Tapstart;
The purpose of collection of personal information, the manner of collection, storage and use of such information;
The parties to whom such personal information is disclosed; and
The security practices and procedures and management of personal information adopted by us to protect your personal information collected by us.

It is important that you read the Privacy Policy carefully because anytime you avail our Services or use/view the Site, you consent to the terms and conditions described in this Privacy Policy. This Privacy Policy does not concern any third-party site that are linked to the Site or pop-ups while using the Site and any products and/or services being provided by such third parties.

Collection of Information

TAPSTART may collect, store and use information about you when you: (a) visit, use, view, and/or otherwise utilize this Site including filling out any form and subscribing to any newsletter; and/or (b) fill any loan application form, whether online or otherwise, when you apply for a loan from Tapstart. Please note that this loan application form may be provided directly by TAPSTART or through any third party sourcing partner; and/or (c) through any other modes and includes the information that you submit directly or indirectly to us for availing the Services.

In the course of using this Site or availing the Services, TAPSTART collects various information including your name, address, email address, phone number, date of birth, occupation and job position, financial information (such as income, income sources, assets, details of debit cards, credit cards, bank account details etc.), medical records, biometric information, documents that you provide to us to verify your identity or in terms of KYC requirements (such as copies of your Aadhaar card, PAN card, passport, utility bills, and/or bank statement). Also, TAPSTART may from time to time undertake your credit evaluation including taking out your CIBIL Score, statement of accounts etc.

Automatically collected information

IP address;
Information about your web browser software and version;
General geographic location indicated by your IP address; and/or
Website that referred you to us, and similar information.

Activity on our Site

Frequency of visits to our Site;
Average length of visits; and/or
Pages viewed during a visit.

We may use various technologies to collect information about your activities on our Site, including Cookies and beacons. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser that enables the sites or service providers’ systems to recognize your browser and capture and remember certain information. By accessing and using the Site, you consent to the storage of cookies, other local storage technologies, beacons and other information on your devices.

Use of collected Personal Information

TAPSTART may use the personal information that is collected from you to provide various Services and for our internal business purposes, including, but not limited to:

Responding to your requests for our products and Services;
Grant of credit facility and to ensure due repayment of the same;
To undertake your credit valuation from time to time to ensure due payment of any loan facility granted to you;
Responding to your requests for information;
Maintaining and managing your account with us;
To personalize your experience (your information helps us to better respond to your individual needs);
To improve our Site (we continually strive to improve our Site offerings based on the information and feedback we receive from you);
To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs);
To process transactions and to provide you with transaction and post transaction-related services;
To administer a contest, promotion, survey or other site feature;
For advertising, such as providing customised and personalised advertisements, sponsored content and sending you promotional or marketing communications;
To send periodic emails;
The email address and phone number you provide may be used to send you information, respond to inquiries, and/or to intimate through phone, e-mail etc. the due date of payments or breach of any contract; and/or
Otherwise with your consent.

By availing any Service, using the Site and/or providing TAPSTART with your information, you consent to the storing of information by TAPSTART and the third parties as mentioned herein. You also consent to collection, transfer, storage and processing of your information outside of India by TAPSTART or any third party.

How We Share Personal Information

TAPSTART may share your information with:

Service Providers

We may disclose your information to companies that provide services for or on behalf of TAPSTART. By using the Site and our Services you authorize us to exchange, share, part with all information related to your details and transaction history to such service providers / credit bureaus / agencies and/or for participation in any telecommunication or electronic clearing network as may be required by applicable law, customary practice, credit reporting, statistical analysis and credit scoring, verification or risk management.

Business Partners

We may share your information with business partners. These entities may use your information to provide you with Services you request, make predictions about your interests and may provide you with promotional materials, advertisements and other materials.

Group Companies

TAPSTART may share collected personal information with group companies / subsidiaries / affiliates whose products and services we believe you may find of interest. If you would prefer that we not share your personal information with any third parties for the third parties’ marketing purposes, you can notify us of your preference by contacting us as described in the “Contact Us” section.

Statutory and other Disclosures

There may be instances when we disclose your information to other parties (including government/regulatory bodies or agencies):

To comply with the law or respond to compulsory legal process (such as a search warrant or other court order) or when we believe release is appropriate to comply with applicable law, enforceable governmental request or to enforce our Site policies;
For the purposes of verification of identity or for prevention, detection, investigation including cyber incidents, prosecution and punishment of offences;
To verify or enforce compliance with the policies governing the Services;
To protect the rights, property, or safety of TAPSTART, or any of TAPSTART’s respective affiliates, business partners, or customers or employees;
For enforcement of any rights of TAPSTART / service provider under any contract / agreement executed by you; and
To investigate, prevent, or take other action regarding illegal activity, suspected fraud, or other wrongdoing.

Marketing

Non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Transactions

TAPSTART may share personal information in connection with a substantial corporate transaction, such as mergers, acquisition, the sale of its business, a divestiture, consolidation, or asset sale, or in the unlikely event of bankruptcy.

Third Parties

For our Site users’ convenience, TAPSTART may provide links or otherwise refer you to third parties, such as operators of internet services linked to from our Site. Personal information collected by these third parties is not covered by this Privacy Policy and TAPSTART shall not be liable for such information being provided by you or collected by such third parties.

Retain Information

We will retain your information for as long as your account is active or as needed to provide you Services and till it is required to be retained to comply with our legal obligations, resolve disputes, and enforce our agreements.

Changes to your Information

If the information provided by you has changed then you may update it by contacting us at hello@tapstart.in. You are also entitled to review the information provided and ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient be corrected or amended as feasible. However, TAPSTART shall not be responsible for the authenticity of the personal information or sensitive personal data or information supplied by you.

No Contractual Obligation

Please note that this Privacy Policy does not create any contractual or other legal rights in or on behalf of any party, nor is it intended to do so.

Personal Information Protection

TAPSTART shall use commercially reasonable security measures (including physical, electronic and procedural measures) to safeguard personal information against loss, misuse, damage or modification and unauthorized access or disclosure.

However, no system for transmitting or storing information electronically can be completely secure. Therefore, we cannot guarantee that personal information or other communications will always remain secure.

Minor’s Privacy

We do not knowingly collect personal information from minor children. If we learn that we have collected personal information from a child who is in the minor category, we will delete that information from our database unless we have authorisation from the guardian of such minor.

Privacy Policy Changes

This Privacy Policy provides a general statement of the ways in which TAPSTART aims to protect your information. TAPSTART may, however, in connection with specific products or Services offered by it, amend statements to this Privacy Policy or supplement this policy with another.

We may also occasionally update this Privacy Policy to reflect changes in our practices concerning the collection and use of your information. We reserve the right to change or update this Privacy Policy and you are suggested to regularly review the Privacy Policy before accessing the Site or otherwise furnishing data to TAPSTART or availing our Services.

Data Protection, Retention and Storage

Pursuant to applicable data protection laws, Tapstart endeavors to protect sensitive personal and personal information and data of the user against accidental or unlawful destruction or loss, alteration, unauthorized disclosure or access. These precautions shall include technical, physical and organizational security measures as defined in our Information Security policy.

You further understand and agree that repayment of a loan / financial facility does not automatically rescind the consents you have provided to us under the Privacy Policy nor does deletion of your account with the Platform.

We shall store your information and/or data for such period as may be required by Tapstart to: (i) enforce its legal rights and obligations against you; (ii) to ensure compliance with its obligations and responsibilities under applicable laws in the capacity of a lender regulated by the Reserve Bank of India. Once your Information and/or data is no longer required, it will be disposed of securely.

We store and process your personal information on cloud servers. Some of the safeguards we use are firewalls and bit data encryption, and information access authorization controls. Information you provide to us may be stored on our secure servers located within India.

We shall take all appropriate action to comply with data security and protection obligations including without limitation, the adoption of appropriate technical and organisational methods to ensure that computer and information systems are safeguarded against accidental destruction, loss, technical malfunction, falsification, theft, unlawful use, unauthorised modification, copying or improper access or any other unauthorised activity.

You agree and acknowledge that your personal data will continue to be stored and retained by us as required or permitted by applicable laws or regulatory requirements, or as required for defending future legal claims. All the other details will be deleted or render the data into anonymised data upon the request of the customer for the deletion of the data, provided there is no active loan or service being availed by you.

Tapstart maintains a comprehensive incident response plan in compliance with the Reserve Bank of India (Non-Banking Financial Companies – Credit Facilities) Directions, 2025. In the unlikely event of a security incident affecting user data, we take immediate action to contain the issue, assess the impact, and notify the Regulators, Partners, and affected users as required under applicable laws.

Disclaimer and Indemnity

EVERYTHING ON THE SITE, ITS CONTENTS, SERVICES AND MATERIALS IN THE SITE ARE PROVIDED “AS IS” AND ON AN “AS AVAILABLE” BASIS WITHOUT REPRESENTATIONS OR WARRANTIES OF ANY KIND EITHER EXPRESS, IMPLIED OR STATUTORY. WE DO NOT MAKE ANY REPRESENTATIONS, WARRANTIES OR ENDORSEMENTS REGARDING THE ACCURACY, RELIABILITY, USEFULNESS OR COMPLETENESS OF THE SERVICES, CONTENT OR MATERIALS IN THE SITE OR ANY SITE LINKED TO IT. TO THE MAXIMUM EXTENT PERMISSIBLE PURSUANT TO APPLICABLE LAW, WE DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT, DESIGN, ACCURACY, CAPABILITY, SUFFICIENCY, SUITABILITY, CAPACITY, COMPLETENESS, AVAILABILITY, COMPATIBILITY OR ARISING FROM COURSE OF DEALING OR COURSE OF PERFORMANCE.

Neither TAPSTART and its affiliates, nor their directors, shareholders, managers, officers, employees, representatives and/or agents shall be liable to you or anyone else for any loss, damage, penalty, expense or any liability arising out of any access to or use of this Site / Services or any site linked to it.

IN NO EVENT SHALL TAPSTART BE LIABLE TO YOU FOR ANY CONSEQUENTIAL, INCIDENTAL, INDIRECT, SPECIAL, PUNITIVE OR EXEMPLARY DAMAGES (INCLUDING, WITHOUT LIMITATION, LOST PROFITS, BUSINESS OR GOODWILL) SUFFERED OR INCURRED BY SUCH OTHER PARTY OR ITS AFFILIATES IN CONNECTION WITH THIS PRIVACY POLICY, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

Governing Law, Dispute Resolution & Jurisdiction

This Privacy Policy shall be governed by and construed in accordance with the laws of the Republic of India and subject to the provisions of arbitration set out herein, the courts at Bangalore shall have exclusive jurisdiction in relation to any disputes arising out of or in connection with this Privacy Policy.

If any dispute arises between you and Tapstart in connection with or arising out of the validity, interpretation, implementation or alleged breach of any provision of this Privacy Policy, such dispute shall be referred to and finally resolved by arbitration in accordance with the Indian Arbitration and Conciliation Act, 1996. There shall be 1 (one) arbitrator and the seat of the arbitration shall be Bangalore, India. The language of the arbitration proceedings shall be English.

Contact Information

In case of any grievance / review of information you may contact the grievance officer Mr. Shaurya Rana on the coordinates provided below:

Address: Tapstart Capital Private Limited, Unit No G408, 4th Floor, Gamma Block, Varthur Hobli Sigma Soft Tech Park, No. 7, Whitefield Road, Bangalore – 560066, Karnataka.

Email: shaurya@tapstart.in

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Compliance & Disclosures

Policies

All regulatory policies, compliance documents and regional language resources mandated by the Reserve Bank of India.

Interest Rate Policy

Background and Introduction

Tapstart Capital Private Limited (hereinafter referred to as “Tapstart” or ‘the Company’ or ‘we’ or ‘us’) is an RBI registered Non-systemically important Non-deposit taking Non-banking Financial company (NBFC-ND-NSI). It provides credit facilities to underserved middle and low income segment customers catering to different needs, including personal loans, medical loans, education loans, consumer electronic loans, consumer lifestyle loans and two-wheeler loans.

The Reserve Bank of India (RBI) has advised Boards of NBFCs to lay out appropriate internal principles and procedures in determining interest rates, processing and other charges. This interest rate policy has been framed in line with the Company’s objectives and the guidelines outlined in the RBI Master Direction – Non-Banking Financial Company – Non-Systemically Important Non-Deposit taking Company (Reserve Bank) Directions, 2016 and updated from time to time. The policy has been duly approved by the Company’s Board of directors and is suitably and periodically reviewed.

Purpose of the Policy

The policy has been framed with the purpose to enable customers to know and understand the methodology for determining the lending rates charged to them and for the Company to maintain transparency in this regard at all times.

Methodology / Approach for Gradation of Risk

The rate of interest under each product charged to different customers is decided from time to time, based on the following parameters:

Cost of Funds

The cost of funds on the borrowings, as well as costs incidental to those borrowings, considering the average tenure, market liquidity etc.

Margin for Business Operation

Considering the industry trends and practices followed by competitors.

Operational Expenses

Operating costs including marketing, acquisition, account management and collections in the business as well as maintaining the stakeholders expectations for a reasonable, market-competitive rate of return.

Risk Profile of Customer

Different information of customers are considered including but not limited to demographics, credit history, geography, product, banking transactions, income etc.

Credit Risk

The cost of credit risk depends upon the internal credit assessment of the borrower including probability of default.

Rate of Interest

The annualised rate of interest** charged to borrowers at the time of sanctioning loans shall be within the range as below:

Sr.No.	Loan Products	Range of Interest Rate*
1.	Short term Personal Loan	Up to 36%
2.	Education Loan	0% to 36%
3.	Consumer Durable Loan	0% to 36%

*Based on the Risk Profile of the Borrower
**In exceptional cases, the rate may fall outside the abovementioned range basis the credit assessment of the borrower.

The abovementioned range shall be reviewed periodically or as and when required by the Board of Directors, keeping in view regulatory guidelines/directives, intensity of competition in the market, net interest margin target, etc.

The interest rates offered is on fixed rate basis
The interest rate will be annualized so that the borrower is aware of the exact rate that would be charged to him
The annualized interest rate, loan amount and the tenor will be communicated to the borrower in the sanction letter
The changes in interest rates and other charges will be effected only prospectively
Interest would be charged, and recovered on a monthly, quarterly basis or such other periodicity as may be determined by the appropriate authority

Penal and Other Charges

The charges currently levied on the customer include:

Line Set up Fees

A one-time flat expense upto ₹999 plus applicable taxes, to be borne by the customer at the first drawdown from the credit limit.

Processing Fee

Basis of tenor chosen for the drawdown and the value of transaction, a flat transaction fee is levied on the customer at each drawdown.

Usage Fees

A usage fee of upto ₹100 + applicable taxes on every drawdown. This fee is applicable from second drawdown onwards.

Penal Charges

In case the customer fails to pay the EMI on the due date, a penal charge may be levied which shall be an amount equivalent to 36% p.a. of the overdue principal.

Bounce Charges

In case the EMI fails on the repayment date due to insufficient funds, a flat bounce charge fee upto ₹500 plus applicable taxes per bounce shall be payable by such customer.

Foreclosure Fees

In case the customer intends to foreclose the loan, a fee upto 5% of the outstanding principal amount is levied on the customer.

Claims for refund or waiver of the aforementioned charges or penal interest will be at the sole discretion of the Company.

Disclosure on the Website

This Interest Rate policy will be displayed on the Company’s website in accordance with the requirement of the RBI guidelines.

Review of the Policy

The Board of directors shall periodically review the policy or on a need-basis i.e. in the event of change in regulatory framework or for business or operational need. Such updates/changes to the policy will be communicated to the relevant staff/relevant stakeholders.

Policy on Restructuring 2.0

Introduction

Tapstart Capital Private Limited is an RBI registered Non-systemically important Non-deposit taking Non-banking Financial company (NBFC-ND-NSI). The Reserve Bank of India (RBI) vide its circular on Resolution Framework – 2.0: Resolution of Covid-19 related stress of Individuals and Small Businesses, dated May 05, 2021 (“RBI Circular”), has directed lending institutions including NBFCs to frame Board approved policies for providing the reliefs mentioned in the RBI Circular to all eligible borrowers.

Considering the economic fallout on account of the COVID-19 pandemic and significant financial stress for borrowers nationwide, the RBI provided a window under the Prudential Framework and enabled the lenders to provide a resolution framework to the eligible borrowers for repayment of their loan by way of restructuring the loan or extending the tenure for repayment of the debt.

Definitions

Term	Definition
Lending Institution	Tapstart Capital Private Limited / the Company.
Board	The Board of Directors or any authorized committee(s) of the board of the Company.
COVID-19	Coronavirus Disease declared as a global pandemic by World Health Organization on 11 March 2020.
Date of Invocation	The date on which both the borrower and lender have agreed to proceed with a resolution plan. In no case shall the Date of Invocation be later than September 30, 2021.

Eligible Borrowers

Individuals who have availed of personal loans, excluding the credit facilities provided by lending institutions to their own personnel/staff;
Individuals who have availed of loans and advances for business purposes and to whom the lending institutions have aggregate exposure of not more than ₹50 crore as on March 31, 2021;
Borrowers whose loan account was classified as Standard as on 31st March, 2021.

Non-Eligible Borrowers

Non-Eligible Borrowers shall mean the personnel or staff of the Company to whom it has extended credit facility or personal loans. The following categories shall also not be eligible:

MSME borrowers whose aggregate exposure to lending institutions collectively is ₹25 crore or less as on March 1, 2020;
Farm credit as listed in relevant RBI Master Directions;
Loans to Primary Agricultural Credit Societies (PACS), Farmers’ Service Societies (FSS) and Large-sized Adivasi Multi-Purpose Societies (LAMPS) for on-lending to agriculture;
Exposures of lending institutions to financial service providers;
Exposures of lending institutions to Central and State Governments; Local Government bodies and body corporates established by an Act of Parliament or State Legislature.

Eligibility for Resolution Under This Policy

Only borrower accounts classified as standard as on March 31, 2021 shall be eligible;
The resolution process shall be treated as invoked when the Company and the borrower agree to proceed with efforts towards finalising a resolution plan;
Resolution plans may include rescheduling of payments, conversion of accrued interest into another credit facility, revisions in working capital sanctions, granting of moratorium etc. However, compromise settlements are not permitted;
The moratorium period, if granted, may be for a maximum of two years. The overall cap on extension of residual tenor, inclusive of moratorium period, shall be two years.

Assessment Norms

Only COVID-19 impacted borrowers (financial/medical impact) shall qualify. Accordingly, any borrower facing financial stress on account of the following shall be eligible:

Income/employment uncertainty;
Impact on business; or
Health issues arising from COVID-19.

The decision on the application shall be communicated in writing to the applicant by the Company within 30 days of receipt of such applications.

Timelines for Resolution

The resolution plan shall be invoked latest by September 30, 2021 and must be implemented within 90 (Ninety) days from the Date of Invocation.

Implementation of Resolution

A restructuring of loan would be treated as implemented upon fulfilment of all of the following conditions:

All related documentation, including execution of necessary agreements between Lender and Eligible Borrower are completed;
The new loan amount and/or changes in the terms and conditions of the existing loan account get duly reflected in the books of accounts of the Lender;
The Eligible Borrower is not in default with the Lender as per the revised terms and conditions.

Asset Classification and Provisioning

If a resolution plan is implemented in adherence to the circular provisions, the asset classification of borrowers’ accounts classified as Standard may be retained as such upon implementation;
Borrowers’ accounts which may have slipped into NPA between invocation and implementation may be upgraded as Standard as on the date of implementation of the resolution plan;
Lending institutions shall keep provisions higher of: the provisions held as per extant IRAC norms immediately before implementation, or 10 percent of the renegotiated debt exposure post implementation (residual debt);
Half of the above provisions may be written back upon the borrower paying at least 20% of the residual debt without slipping into NPA post implementation, and the remaining half upon the borrower paying another 10% of the residual debt.

Disclosures and Credit Reporting

Financial Statement: The Company shall make appropriate disclosures about restructured accounts in its annual financial statements under “Notes to Accounts”;
Credit Reporting: Credit bureau reporting shall reflect the “restructured due to COVID-19” status of the account.

Grievance Redressal

The Company shall address all grievances of Borrowers who have applied for or are undergoing resolution under this window. Customers can register/lodge grievances via:

Email: hello@tapstart.in
Post: Customer Services Team, Tapstart Capital Private Limited, Unit No G408, 4th Floor, Gamma Block, Varthur Hobli, Sigma Soft Tech Park, No. 7, Whitefield Road Bangalore – 560066

Grievance Redressal Officer

DesignationGrievance Redressal Officer

NameKshama Kottachery

Contact No.+91-6366916645 (10:00 am – 7:00 pm, working days)

Emailkshama@tapstart.in

Review/Amendment of the Policy

In case of any further clarifications issued by RBI from time to time, the same shall override/amend this policy as applicable. In order to ensure immediate implementation keeping in view the importance of extending relief due to the impact of COVID-19, any further changes to this policy based on the notifications from the RBI in this regard, can be done with approval from MD and CEO ABFL, CRO. Any significant changes will be informed to the Board.

Download Restructuring Policy_2.0_1_06_2021

Loan Application Form in Regional Languages

Download the TapStart Personal Loan Application Form in your preferred regional language.

English বাংলা ગુજરાતી हिन्दी ಕನ್ನಡ മലയാളം मराठी தமிழ்తెలుగు

Grievance Redressal Policy

Background and Introduction

Tapstart Capital Private Limited (hereinafter referred to as “Tapstart” or ‘the Company’) is an RBI registered NBFC-ND-NSI and NBFC-BL. It provides credit facilities to underserved middle and low income segment customers catering to different needs, including personal loans, medical loans, education loans, consumer electronic loans, consumer lifestyle loans and two-wheeler loans.

Tapstart places utmost importance on customer satisfaction and endeavors to provide prompt and efficient customer service. The Grievance Redressal Policy has been framed in line with the Company’s objectives and the guidelines outlined in the RBI Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023 and updated from time to time. The policy has been duly approved by the Company’s Board of directors and is suitably and periodically reviewed.

Purpose of the Policy

To ensure that all customers are treated fairly and in a professional manner;
To provide redressal of customer grievances and complaints in a time-bound manner; and
To ensure that all customers are fully informed of the grievance redressal mechanism including the mode of lodging complaints, escalation matrix with all the contact details, and timelines for redressal at every level.

Grievance Redressal Mechanism

The Company will address all complaints/concerns of customers arising out of activities carried out by the Company as well as those activities that have been outsourced including digital lending through Mobile Applications of Lending Service Provider (LSP). Customers can register/lodge complaints via:

Email: hello@tapstart.in — looked into by the Company’s operations/back-end team internally.
Post: Customer Services Team, Tapstart Capital Private Limited, Unit No G408, 4th Floor, Gamma Block, Varthur Hobli, Sigma Soft Tech Park, No. 7, Whitefield Road Bangalore – 560066

Timeframe for Redressal

Within 15 days from date of receipt of complaint. If additional time is needed, the customer will be informed promptly.

Acknowledgement

Communicated to the customer within 2 days with a Complaint Reference Number to be quoted on all correspondence.

Recording of Complaints

All complaints are filed in a Complaints Register with a unique Complaint Reference Number generated at the time of filing.

Escalation Matrix

A step-by-step flow showing how you can raise and escalate a complaint with Tapstart. Each level has a defined contact, response time, and escalation path.

Complaint escalation flow

Registration of complaint

or grievance

MAIL ID

hello@tapstart.in

Grievance Redressal Officer

EMAIL ID

shaurya@tapstart.in

CONTACT NO.

+91-8095345443

Officer-in-Charge DNBS, RBI

ONLINE PORTAL

cms.rbi.org.in

cms.cepcbengaluru@rbi.org.in

TELEPHONE (RBI CEPC BENGALURU)

080-2218 0397 / 398 / 399 / 357

Note: If the borrower is not satisfied with the reply or has not received any reply within 30 days of receipt of complaint by the RE, the borrower may lodge a complaint with the Officer-in-Charge DNBS, RBI through the Complaint Management System (CMS) portal under the Reserve Bank Integrated Ombudsman Scheme (RB-IOS), by email at cms.cepcbengaluru@rbi.org.in or cepcbengaluru@rbi.org.in, or by telephone at RBI CEPC Bengaluru – 080-2218 0397 / 398 / 399 / 357.

Level 1: Grievance Redressal System

All complaints against the Company or the Lending Service Provider engaged by the Company shall be initiated through/directed to any of the channels mentioned above. At this level, the Company will strive to address the customer complaint within 7 days.

Level 2: Grievance Redressal Officer

If any such complaint is not addressed to the satisfaction of the customer, the customer shall be given the option to escalate the complaint to the Grievance Redressal Officer (‘GRO’) who will be a senior level officer appointed by the Company. After examining the matter, the Company will endeavor to respond or address the customer complaint within 15 days of receipt of the complaint/grievance.

The customer can lodge a complaint related to unauthorized acceptance of deposits/schemes of various kind and fake emails at https://sachet.rbi.org.in/home/index

DesignationGrievance Redressal Officer

NameMr. Shaurya Rana

Contact No.+91-8095345443 (10:00 am – 7:00 pm, working days)

Emailshaurya@tapstart.in

Level 3: Officer-in-Charge DNBS, RBI

If any complaint lodged by the borrower is rejected wholly or partly, or the borrower is not satisfied with the reply, or has not received any reply within 30 days of receipt of complaint, the said borrower can lodge a complaint via:

(i) The Complaint Management System (CMS) portal https://cms.rbi.org.in/ under the Reserve Bank Integrated Ombudsman Scheme (RB-IOS);
(ii) Physical complaint to “Centralised Receipt and Processing Centre, 4th Floor, Reserve Bank of India, Sector-17, Central Vista, Chandigarh – 160017”;
(iii) Email: cms.cepcbengaluru@rbi.org.in, cepcbengaluru@rbi.org.in
(iv) Telephone: RBI CEPC Bengaluru – 08022180397 / 398 / 399 / 357 | Fax: 080-2223 2199

Mandatory Display Requirements

The Company shall prominently display the escalation matrix of the internal Grievance Redressal Mechanism, the name of the GRO along with all the contact details, and the details of the Officer-in-Charge DNBS, RBI over its website, mobile applications as well as across all branches/places where its business is transacted.

Training of Employees

The Company shall adequately train all its employees and agents to appropriately address customer concerns and complaints in a professional manner. The training programme shall include soft skills and technicalities around nature of complaints and shall inter alia include a module containing the rights of persons with disabilities guaranteed to them by law and international conventions.

Responsibility of Board

To approve the policy as well as any revisions/modifications made therein;
To lay down the appropriate grievance redressal mechanism within the organization and effective implementation thereof;
To periodically review the functioning of the grievance redressal mechanism at various levels of management;
To prescribe a consolidated report of such reviews to be submitted to it at regular intervals;
To prescribe and review a complaint MIS/register on a periodic basis.

Review of the Policy

Fair Practice Code

Regional Language Downloads

Download the Fair Practice Code in your preferred regional language.

বাংলা ગુજરાતી हिन्दी ಕನ್ನಡ മലയാളം मराठी தமிழ்తెలుగు

Background and Introduction

Tapstart Capital Private Limited (hereinafter referred to as “Tapstart” or ‘the Company’) is an RBI registered Base Layer (Non-Deposit taking) Non-Banking Financial Company (“NBFC-ND”). We provide a host of credit services to customers catering to different needs, including personal loans, medical loans, education loans, consumer electronic loans, consumer lifestyle loans and two-wheeler loans. We primarily target underserved middle and low-income segments with a relatively high credit need. We endeavor to maintain transparency in all our dealings with the customer.

This Fair Practice Code (‘the Code’) has been formulated in line with the Company’s objectives and the guidelines outlined in the Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023 and updated from time to time. The Code applies to all categories of products offered by the Company as well as to all its customers. The Code has been duly approved by the Company’s Board of directors and shall be circulated to all employees and agents of the Company.

Key Commitments

The Code has been framed with the purpose of committing to the following:

To ensure that all customers are treated fairly and in a professional manner;
To provide in detail about the features of the products and services to the customer so that they can make an informed decision;
To ensure that customers are not discriminated on the basis of gender, race or religion;
To quickly and efficiently address customer concerns;
To ensure that the Company’s products, practices and procedures confirm to the relevant laws and regulations;
To appropriately train all staff, employees and agents to deal with customers in a professional and kind manner;
To establish a transparent charge structure;
To ensure that all customers are made aware of all the terms and conditions around interest rates, costs, penalties and other important aspects of the loans disbursed to them.

Applications for Loans and Their Processing

The Company shall ensure that all communications to the customers shall be in English or in a vernacular language or a language as understood by the customer. Additionally, the Company shall ensure that all loan application forms include necessary information which affects the interest of the customer.

An acknowledgement for receipt shall be generated for all loan applications, communicating the time frame within which loan applications will be disposed of.

Loan Appraisal and Terms & Conditions

Sanction Letter

Once a loan has been approved, the Company shall convey in writing to the borrower the amount of loan sanctioned along with the terms and conditions stipulated therein. The terms and conditions shall include the annualised rate of interest and method of application thereof. The Company shall maintain a record of the acceptance of these terms and conditions by the customer. The rate of interest and the approach for gradations of risk shall be communicated to the customer explicitly in the sanction letter.

Loan Agreement and Disbursement of Loans

The Company shall furnish a copy of the loan agreement as understood by the borrower along with a copy each of all enclosures, to all customers at the time of sanction/disbursement of loans. With regard to the loan agreement, the Company shall ensure:

To give notice to the borrower of any change in the terms and conditions including disbursement schedule, interest rates, service charges, prepayment charges etc.;
To ensure that the penal charges for late repayment is mentioned in ‘bold’;
To incorporate a suitable condition that all changes pertaining to interest rates and charges are effected only prospectively;
That the decision to recall/accelerate payment or performance under the agreement shall be in consonance with the loan agreement;
To release all securities on repayment of all dues or on realisation of the outstanding amount of loan;
If the Company decides to exercise its right of set off, it shall give the customer notice about the same with full particulars about the remaining claims.

Key Facts Statement (KFS)

Once the loan is approved, a KFS shall be issued to the borrower in a standardised format as per the RBI circular on Key Facts Statement for Loans & Advances dated April 15, 2024.

A KFS is a statement of key facts of a loan agreement, in simple and easier to understand language, provided to the borrower in a standardised format. It shall be provided to the borrower before the execution of the loan agreement. The contents of KFS shall be explained to the borrower and an acknowledgement shall be obtained.

The KFS shall be provided with a unique proposal number and shall have a validity period of at least three working days for loans having tenor of seven days or more, and a validity period of one working day for loans having tenor of less than seven days. The KFS shall inter alia contain the details of APR, the recovery mechanism, details of grievance redressal officer designated specifically to deal with digital lending/FinTech related matter and the cooling-off/look-up period.

Penal Charges in Loan Accounts

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.

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. 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.

The quantum and reason for penal charges shall be clearly disclosed to customers in the loan agreement and Key Fact Statement (KFS), in addition to being displayed on the Company’s website under Interest rates and Service Charges.

Repossession of Vehicles Financed by Tapstart

To ensure transparency, the terms and conditions of the loan agreement shall inter alia contain provisions pertaining to:

Notice period before taking possession;
Circumstances under which the notice period can be waived;
The procedure for taking possession of the security;
A provision regarding final chance to be given to the customer for repayment of loan before the sale/auction of the property;
A legally enforceable repossession clause;
The procedure for sale/auction of the property.

Loan Facilities to the Physically/Visually Challenged

The Company shall not discriminate in extending products and facilities including loan facilities to physically/visually challenged applicants on grounds of disability. The Company shall render all possible assistance to such persons for availing of the various business facilities. The Company shall include a suitable module containing the rights of persons with disabilities guaranteed by law and international conventions in all training programmes. Further, the Company shall ensure redressal of grievances of persons with disabilities under the Grievance Redressal Mechanism.

General Fair Practices

The Company shall refrain from interfering in the affairs of the customer except for the purposes provided in the terms and conditions of the loan agreement;
In case the customer requests a transfer of the borrowal account, the Company shall convey its consent or objection, if any, within 21 days from the date of receipt of such request;
With respect to recovery of loans, the Company shall not resort to undue harassment and shall refrain from persistently bothering customers at odd hours or using muscle power for recovery of loans;
The Company shall not charge foreclosure charges/pre-payment penalties on any floating rate term loan sanctioned for purposes other than business to individual customers, with or without co-obligant(s).

Complaint Redressal Mechanism

The Company will address all complaints/concerns of customers arising out of activities carried out by the Company as well as those activities that have been outsourced including any complaints against the Lending Service Provider (LSP) engaged by the Company.

DesignationGrievance Redressal Officer

NameMr. Shaurya Rana

Contact No.+91-8095345443 (10:00 am – 7:00 pm, working days)

Emailshaurya@tapstart.in

If any complaint lodged by the borrower is rejected wholly or partly, or the borrower is not satisfied with the reply, or has not received any reply within 30 days, the said borrower can lodge a complaint via:

(i) The Complaint Management System (CMS) portal https://cms.rbi.org.in/ under the Reserve Bank Integrated Ombudsman Scheme (RB-IOS);
(ii) Physical complaint to “Centralised Receipt and Processing Centre, 4th Floor, Reserve Bank of India, Sector-17, Central Vista, Chandigarh – 160017”;
(iii) Email: cms.cepcbengaluru@rbi.org.in, cepcbengaluru@rbi.org.in
(iv) Telephone: RBI CEPC Bengaluru – 08022180397 / 398 / 399 / 357 | Fax: 080-2223 2199

Transparency in Computation of Interest Rate and Charge Structure

The Board of the Company shall lay out and implement 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 rates of interest and the approach for gradation of risks shall also be made available on the website/mobile application of the Company or published in relevant newspapers. The information so published will be updated whenever there is a change in the rates of interest. The rate of interest shall be an annualised rate for the benefit of the customer.

Training of Employees and Agents

The Company shall adequately train all its employees, Direct Sales Agents (DSA), Direct Marketing Agents (DMA) and Recovery Agents to appropriately handle their responsibilities with care and sensitivity, particularly aspects such as soliciting customers, hours of calling, privacy of customer information and conveying the correct terms and conditions of the products on offer.

The training shall be formulated to ensure that the Company and its agents shall not resort to rudeness, intimidation or harassment of any kind, either verbal or physical, against any person in their debt collection efforts, including acts intended to humiliate publicly or intrude the privacy of the debtors’ family members, referees and friends, making threatening and anonymous calls or making false and misleading representations.

Mandatory Display Requirements

The Company shall display, in English or in a vernacular language or a language as understood by the customer, the Fair Practice Code as well as the contact information of the GRO across its website, mobile applications as well as across all branches/places where its business is transacted.

Review of the Code

The Board of directors shall periodically review the Code and the functioning of the grievances redressal mechanism on a need-basis i.e. in the event of change in regulatory framework or for business or operational need. Such updates/changes to the Code will be communicated to the relevant customers/staff/relevant stakeholders.

Sanction Letter in Regional Languages

Download the TapStart Sanction Letter in your preferred regional language.

English বাংলা ગુજરાતી हिन्दी ಕನ್ನಡ മലയാളം मराठी தமிழ்తెలుగు

Consumer Education Literature

PREFACE:

Reserve Bank of India (RBI) vide its circular dated November 12, 2021 on Prudential norms on Income Recognition, Asset classification and provisioning pertaining to Advances (IRACP norms) has harmonized/clarified certain aspects of the extant regulatory guidelines applicable to NBFCs in order to ensure uniformity in the implementation of IRACP norms across all lending institutions.

Tapstart Capital Private Limited (Tapstart or “the Company”), is a Base – Layer, non-deposit taking, Non-Banking Financial Company (“NBFC-BL”) and will follow the above norms.

With a view to increase an awareness among the borrowers, RBI requires the NBFCs to frame Consumer Education Literature explaining with examples the concepts of date of overdue, SMA and NPA classification and upgradation, with specific reference to day-end process.

CONSUMER EDUCATION LITERATURE:

Overdue and date of overdue:

Any amount due to the Company under any credit facility shall be treated as overdue if it is not paid on the due date fixed by the Company. Borrower accounts shall be flagged as overdue by the Company as a part of the day-end process for the due date and date of overdue shall be calendar date for which the day-end process is run.

Example: If the due date of a loan account is March 31, 2021 and full dues are not received before the Company runs the day-end process for this date, the date of overdue shall be March 31, 2021.

Classification as Special Mention Account (SMA):

Classification of the borrower accounts as SMA shall be done as part of day-end process for the relevant date and the SMA classification date shall be the calendar date for which the day-end process is run.

The basis for classification of SMA categories shall be as follows:

SMA sub-categories	Basis for classification – Principal or interest payment or any other amount wholly or partly overdue
SMA-0	Upto 30 days
SMA-1	More than 30 days and upto 60 days
SMA-2	More than 60 days and upto 90 days

Example: If due date of a loan account is March 31, 2021, and if it continues to remain overdue, then this account shall get tagged as SMA-1 upon running day-end process on April 30, 2021 i.e. upon completion of 30 days of being continuously overdue. Accordingly, the date of SMA-1 classification for that account shall be April 30, 2021. Similarly, if the account continues to remain overdue, it shall get tagged as SMA-2 upon running day-end process on May 30, 2021.

Classification as Non-Performing Asset (NPA):

Classification of the borrower accounts as NPA shall be done as part of day-end process for the relevant date and the NPA classification date shall be the calendar date for which the day-end process is run.

NPA means:

an asset, in respect of which, interest has remained overdue for such period as may be prescribed by RBI from time to time;
a term loan inclusive of unpaid interest, when the installment is overdue for such period as may be prescribed by RBI from time to time;
a demand or call loan, which remained overdue for such period as may be prescribed by RBI from time to time;
a bill which remains overdue for such period as may be prescribed by RBI from time to time;
the interest in respect of a debt or the income on receivables under the head ‘other current assets’ in the nature of short term loans/advances, which facility remained overdue for such period as may be prescribed by RBI from time to time;
any dues on account of sale of assets or services rendered or reimbursement of expenses incurred, which remained overdue for such period as may be prescribed by RBI from time to time;
the lease rental and hire purchase installment, which has become overdue for such period as may be prescribed by RBI from time to time; and
in respect of loans, advances and other credit facilities (including bills purchased and discounted), the balance outstanding under the credit facilities (including accrued interest) made available to the same borrower/beneficiary when any of the above credit facilities becomes nonperforming asset.

Example: If the due date of a loan account is March 31, 2021 and if it continuous to remain overdue till June 29, 2021, then the borrower account will be classified as NPA as on June 29, 2021 upon running day-end process on June 29, 2021.

Upgradation of accounts classified as NPA:

It is said that loan accounts classified as NPAs may be upgraded as ‘standard’ asset only if entire arrears of interest and principal are paid by the borrower.
In case if the borrower is having more than one credit facilities, the loan account will be upgraded from NPA to standard category only when entire principal and interest outstanding amount pertaining to all credit facilities is paid by the borrower.
No delinquency should be present in any of the credit facilities availed by the borrower from the Company.

NACH Mandate Cancellation Form

Download the NACH (National Automated Clearing House) Mandate Cancellation Form to cancel your existing NACH mandate with TapStart Capital Private Limited.

Download NACH Mandate Cancellation Form (PDF)

What Our Customers Say

Join thousands of satisfied customers who trust TapStart for their financial needs.

“When my mother was admitted to the hospital unexpectedly, I needed funds immediately. TapStart helped me get the money quickly without any complicated paperwork. It allowed me to focus on my parents instead of worrying about finances.”

Amit Verma

Senior Executive, Indore

“My son’s school fee payment was due, and I was facing a temporary cash shortage. TapStart made the process simple and fast. The funds were available when I needed them, ensuring my child’s education continued without any interruptions.”

Neha Singh

HR Executive, Jabalpur

“The personal loan feature is amazing. I only pay for what I use, and it’s always available when I need it. Whether it’s an unexpected expense or a planned purchase, TapStart gives me the flexibility and confidence to manage my finances better.”

Sandeep Kumar

Operations Manager, Hubballi

Type of credit	One-time disbursement
Loan limits	Up to Rs 5 Lakhs
Type of interest rate	Interest Rate varies based on your risk profile (13%–36% per annum)
Fees	Processing fees and late fees
Term Length	3 years
Repayment	Monthly
Funding Method	Lump-sum amount

Name	MoneyTap
Developer Details	MWYN Tech Pvt Ltd No.7, Whitefield Main Rd, Varthur Kodi, Palm Meadows, Whitefield, Bengaluru, Karnataka 560066
Services Offered	1.Advertising and Marketing 2.Assistance in Development, Disbursement & Management of Loan Products 3.Loan Origination & Customer Acquisition 4.Initial Background Checking, Pre-assessment & Fraud Assessment 5.Assistance in Know Your Customer Process 6.Collection and Recoveries 7.Customer Support
Grievance Redressal Officials	Grievance Redressal Officer Ms. Anjali Panwar +91-80-40974095 hello@moneytap.com
Website	https://www.moneytap.com

Name	Freo
Developer Details	MWYN Tech Pvt Ltd No.7, Whitefield Main Rd, Varthur Kodi, Palm Meadows, Whitefield, Bengaluru, Karnataka 560066
Services Offered	1.Advertising and Marketing 2.Assistance in Development, Disbursement & Management of Loan Products 3.Loan Origination & Customer Acquisition 4.Initial Background Checking, Pre-assessment & Fraud Assessment 5.Assistance in Know Your Customer Process 6.Collection and Recoveries 7.Customer Support
Grievance Redressal Officials	Grievance Redressal Officer Ms. Anjali Panwar +91-80-40974095 hello@freo.money
Website	https://freo.money/

Name	Chinmay Finlease Limited
Address	Floor 3rd & 4th, House no 14, Times Corporate Park, Thaltej, Ahmedabad – 380059
Services Offered	1.Instant Personal Loan 2.Consumer Durable Loan 3.Emergency Loan 4.Collection and Recoveries 5.Customer Support
Grievance Redressal Officials	Grievance Redressal Officer Mr. Satvinder Singh Huda +91-7948519054 grievance@chinmayfinlease.com
Website	https://www.chinmayfinlease.com/

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