TRUEFIN CHITS PRIVATE LIMITED
(A Company incorporated under the Companies Act, 2013)
1. INTRODUCTION
1.1 TrueFIN Chits Private Limited (“TrueFIN”, “Company”, “we”, “us” or “our”), a company incorporated under the Companies Act, 2013, bearing CIN U64990TN2025PTC183946 and registered under The Chit Funds Act, 1982 with The Deputy Registrar of Chits, Chennai Central, Royapettah, Chennai-600014 vide Certificate Reference No. CFR/Chennai Central/4/2025 dated 31-10-2025 having its registered office at First Floor, No. 43, Medavakkam Tank Road, Kilpauk, Chennai – 600010, Tamil Nadu, India, is committed to protecting the privacy, confidentiality and security of the personal data entrusted to it by its subscribers, prospective subscribers, customers, visitors to its website and other individuals who interact with the Company.
1.2 This Privacy Policy (“Policy”) sets out the manner in which TrueFIN collects, receives, uses, processes, stores, retains, discloses and protects personal data in connection with its website www.truefinchits.com (“Website”), digital platforms, applications, products and services, customer interactions and the Company's Chit Fund business and related activities.
1.3 This Policy is intended to provide transparency regarding the Company's data processing practices and should be read together with the Company's Terms and Conditions, applicable Chit Agreement, scheme-specific terms, application forms, KYC documentation, consent notices and other contractual or statutory documents applicable to the relevant service or transaction.
1.4 TrueFIN processes personal data in accordance with the Digital Personal Data Protection Act, 2023, the Digital Personal Data Protection Rules, 2025, to the extent applicable and in force from time to time, the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, the Chit Funds Act, 1982, the Tamil Nadu Chit Funds Rules, 1984, and other applicable laws, rules, regulations, notifications, circulars, directions and governmental or regulatory requirements, as amended or replaced from time to time.
1.5 By providing personal data to TrueFIN, you acknowledge that you have read and understood this Policy.
2. PERSONAL DATA COLLECTED BY TRUEFIN
2.1 TrueFIN may collect and process personal data relating to an individual's identity and contact details, including name, date of birth, photograph, gender where required, mobile, telephone number, email address, residential or correspondence address and other information necessary to establish identity and communicate with the individual.
2.2 In connection with customer identification, KYC and regulatory requirements, TrueFIN may collect and process PAN, Aadhaar or masked Aadhaar, voter identification card, passport, driving licence, proof of address and other officially recognised identity or address documents, as may be applicable to the relevant transaction or service. Where Aadhaar information is collected or verified, the same shall be handled in accordance with applicable law and the requirements applicable to the relevant process. TrueFIN shall not mandate Aadhaar as the sole means of identification and shall accept any other officially valid document as an alternative, in accordance with the Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016 and other applicable laws.
2.3 Depending upon the nature of the chit subscription, transaction or service, TrueFIN may also collect financial and income-related information, including occupation, source of income, income details, bank account details, bank statements, financial documents and other information that may be required for verification, assessment, payment processing, prize disbursement, dividend payout, security creation, compliance or administration of the relevant chit.
2.4 Where applicable, TrueFIN may collect personal data relating to nominees, legal heirs, claimants, authorised representatives, sureties, guarantors or other persons whose information is reasonably necessary for establishing, administering, securing, settling or enforcing a chit-related transaction or claim.
2.5 TrueFIN may also collect payment and transaction-related information, including payment amounts, transaction dates, transaction references, payment status, mode of payment, bank account details and information required for reconciliation and record-keeping. Payment credentials such as card or banking credentials may be processed directly by authorised payment service providers and financial institutions and may be subject to their respective terms and privacy policies.
2.6 TrueFIN may further process information contained in communications with the Company, including enquiries, applications, correspondence, complaints, feedback, customer-support requests and documents submitted by individuals. Where permitted by applicable law and appropriately notified, communications with customers may also be recorded or retained for quality assurance, security, dispute resolution, fraud prevention and record-keeping purposes.
2.7 When an individual accesses or uses the Website or digital services, TrueFIN may also collect certain technical information, including IP address, browser type, operating system, device information, access times, pages visited, referring URLs and information relating to the security, performance and usage of the Website.
3. PURPOSES OF PROCESSING PERSONAL DATA
3.1 TrueFIN may process personal data for purposes connected with the establishment, administration and operation of its business and the provision of its services.
3.2 Personal data may be processed for responding to enquiries, processing registrations and applications, providing information regarding chit schemes and services, communicating with prospective and existing subscribers and administering the relationship between the Company and its customers.
3.3 Personal data may also be processed for undertaking identity verification, KYC, due diligence and other verification procedures; establishing and administering chit groups; maintaining subscriber records; processing payments; conducting and administering auctions; calculating and disbursing prize amounts and other amounts payable; maintaining securities and supporting documentation; processing claims; and managing defaults and other matters arising in connection with the relevant chit.
3.4 Personal data may also be processed for communicating payment reminders, receipts, KYC requirements, auction-related information, account information, statutory notices, service updates, security alerts and other communications necessary for administering the relationship with the subscriber.
3.5 TrueFIN may further process personal data for preventing, detecting and investigating fraud, impersonation, unauthorised transactions, cyber incidents, misuse of the Company's systems and other unlawful or suspicious activities.
3.6 The Company may process personal data where necessary to comply with applicable legal, regulatory, statutory, accounting, taxation, audit and reporting requirements, including requirements applicable to the Company's chit fund operations and requirements relating to furnishing information to the Registrar of Chits and other competent authorities.
3.7 Personal data may also be processed for investigating and resolving complaints, disputes and grievances, establishing, exercising or defending legal rights and claims, and complying with orders or directions issued by courts, tribunals, governmental authorities or regulatory bodies.
3.8 Where appropriate, TrueFIN may use information for analysing and improving its Website, digital interfaces, operational processes, products and customer experience. Such analysis may, where appropriate, be undertaken using aggregated or anonymised information.
4. BASIS OF PROCESSING
4.1 TrueFIN shall process personal data only for a lawful purpose and in accordance with the Digital Personal Data Protection Act, 2023 and other applicable laws.
4.2 Depending upon the nature of the processing activity, personal data may be processed on the basis of consent obtained from the relevant Data Principal in accordance with applicable law, for a purpose recognised as a legitimate use under the Digital Personal Data Protection Act, 2023, for compliance with applicable legal or regulatory requirements, for purposes connected with the performance, administration or enforcement of contractual or chit-related obligations to the extent permitted by applicable law, or on any other lawful basis recognised under applicable law.
4.3 Where consent is required, TrueFIN shall provide an appropriate notice describing the personal data proposed to be processed and the purpose for which such personal data is proposed to be processed and shall provide an appropriate mechanism for giving, managing or withdrawing consent, as required under applicable law.
5. DISCLOSURE AND SHARING OF PERSONAL DATA
5.1 TrueFIN does not sell or rent personal data to third parties.
5.2 The Company may disclose or otherwise make personal data available where such disclosure is reasonably necessary for providing its services, administering a chit, complying with applicable law, protecting the Company's legitimate rights and interests, preventing fraud or ensuring the security and integrity of its systems.
5.3 Personal data may be disclosed to the Registrar of Chits, governmental authorities, regulatory authorities, tax authorities, courts, tribunals, law enforcement agencies and other competent authorities where such disclosure is required or permitted under applicable law.
5.4 The Company may also share relevant personal data with banks, payment gateways, payment processors and other financial service providers where necessary to process payments, verify transactions, undertake reconciliation or facilitate disbursement of amounts.
5.5 TrueFIN may engage advocates, auditors, accountants, consultants, professional advisers and other service providers where access to personal data is reasonably necessary for providing professional or operational services to the Company.
5.6 The Company may also engage technology and service providers, including hosting providers, cloud service providers, KYC and verification service providers, cybersecurity providers, communication service providers, customer-support providers and software providers. Where such parties process personal data on behalf of TrueFIN, the Company shall seek to ensure that appropriate contractual, organisational and security safeguards are implemented in accordance with applicable law.
5.7 Where personal data is transferred outside India, whether to affiliates, service providers or otherwise, TrueFIN shall undertake such transfer in accordance with applicable law, including any restrictions notified by the Central Government under the Digital Personal Data Protection Act, 2023 once in force, and the requirements of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 in the interim.
6. DATA SECURITY
6.1 TrueFIN maintains reasonable technical and organisational security measures appropriate to the nature of personal data processed by it and the risks associated with such processing.
6.2 The Company may implement measures including access controls, authentication mechanisms, restricted access, secure transmission, encryption where appropriate, system monitoring, logging, vulnerability management, backups, recovery mechanisms and confidentiality obligations applicable to employees, consultants and service providers.
6.3 Notwithstanding the security measures implemented by the Company, no electronic transmission, communication system or method of storage over the internet can be guaranteed to be completely secure. Accordingly, while TrueFIN takes reasonable measures to protect personal data against unauthorised access, loss, misuse, alteration or disclosure, the Company cannot guarantee absolute security.
6.4 Users are responsible for maintaining the confidentiality of passwords, OTPs, authentication credentials and other information used to access their accounts or services and should promptly notify the Company if they become aware of any suspected unauthorised access, misuse or fraudulent activity.
7. RETENTION OF PERSONAL DATA
7.1 TrueFIN shall retain personal data only for as long as is reasonably necessary for the purpose for which such personal data was collected or processed or for such longer period as may be required or permitted under applicable law.
7.2 The applicable retention period may depend upon the nature of the information, the duration of the subscriber or contractual relationship, chit-related record-keeping requirements, KYC and regulatory requirements, accounting and taxation requirements, audit requirements, payment and transaction records, complaints and disputes, legal proceedings, fraud prevention and security requirements and other statutory or regulatory obligations.
7.3 Upon expiry of the applicable retention period, and where there is no continuing lawful purpose or legal requirement for retaining the information, TrueFIN shall take reasonable steps to securely delete, anonymise or otherwise dispose of such personal data in accordance with its applicable data retention and deletion procedures.
7.4 A request for deletion shall not require the Company to delete personal data that the Company is required to maintain records or otherwise lawfully permitted to retain.
8. RIGHTS OF DATA PRINCIPALS
8.1 Subject to the applicable laws, a Data Principal may exercise rights in relation to his or her personal data, including the right to obtain information regarding the personal data being processed by the Company and the manner in which such personal data is being processed, to the extent provided under applicable law.
8.2 A Data Principal may request correction, completion or updating of personal data that is inaccurate, incomplete or outdated, subject to applicable law and the Company's obligation to verify the relevant request.
8.3 Subject to applicable law, a Data Principal may nominate another individual to exercise applicable rights in the event of the Data Principal's death or incapacity.
8.4 A Data Principal may also raise a grievance with the Company in relation to the processing of personal data and may exercise such further statutory remedies as may be available under applicable law.
9. CHILDREN'S PERSONAL DATA
9.1 TrueFIN does not knowingly seek to collect or process the personal data of children except where such processing is permitted or required under applicable law.
9.2 Where processing of the personal data of a child is undertaken, TrueFIN shall comply with the requirements applicable to children's personal data under the Digital Personal Data Protection Act, 2023 and the Digital Personal Data Protection Rules, 2025, including obtaining verifiable consent from the parent or lawful guardian where required.
9.3 The Company shall not knowingly undertake any processing of children's personal data that is prohibited under applicable law.
10. COOKIES AND SIMILAR TECHNOLOGIES
10.1 The Website may use cookies and similar technologies to enable essential Website functionality, maintain user sessions, enhance security, remember preferences, analyse Website performance and improve user experience.
10.2 Where applicable law requires consent for the use of particular cookies or similar technologies, TrueFIN shall provide an appropriate mechanism for obtaining such consent.
10.3 Users may manage or disable cookies through their browser or device settings. Disabling certain cookies may affect the functionality, availability or performance of certain portions of the Website.
11. THIRD-PARTY WEBSITES
11.1 The Website may contain links to websites, applications or services operated by third parties.
11.2 Such links are provided for convenience and do not constitute an endorsement, representation or warranty by TrueFIN concerning such third-party websites or services.
11.3 TrueFIN does not control the privacy practices, security arrangements or content of third-party websites and shall not be responsible for the manner in which such third parties collect, use, process or disclose personal data.
11.4 Users are advised to review the privacy policies and terms applicable to third-party websites before providing personal data to them.
12. COMMUNICATIONS AND MARKETING
12.1 TrueFIN may communicate with subscribers and prospective subscribers for purposes directly connected with the administration of its services and business relationship, including payment reminders, receipts, KYC requirements, auction-related communications, account information, security alerts, service notifications, statutory notices and other necessary communications.
12.2 Where permitted under applicable law, the Company may also communicate information regarding its products, services, schemes or promotional activities.
12.3 Where consent is required for promotional communications, the Company shall obtain such consent in accordance with applicable law. A Data Principal may opt out of promotional communications through the mechanism provided in the relevant communication.
12.4 Withdrawal or refusal of promotional communications shall not prevent TrueFIN from sending communications that are necessary for providing services, administering a chit, complying with legal obligations, protecting the security of an account or communicating important transactional or statutory information.
13. PERSONAL DATA BREACHES
13.1 TrueFIN maintains reasonable procedures for identifying, assessing, containing, investigating and responding to personal data breaches and other information-security incidents.
13.2 Where a personal data breach occurs and notification is required under applicable law, TrueFIN shall take such steps as may be required, including notifying the relevant Data Principal, governmental authority or regulatory authority in the manner and within the timelines prescribed under applicable law. Where required under the Information Technology Act, 2000 and the directions issued by the Indian Computer Emergency Response Team (“CERT-In”) thereunder, TrueFIN shall report reportable cybersecurity incidents to CERT-In within six hours of becoming aware of such incident. Once the relevant provisions of the Digital Personal Data Protection Act, 2023 come into force, TrueFIN shall additionally intimate the Data Protection Board of India without delay, and in any event within seventy-two hours of becoming aware of the breach, and shall notify affected Data Principals without delay.
13.3 The Company may take appropriate measures to contain and mitigate the impact of a security incident, including restricting access, securing affected systems, resetting credentials, preserving relevant records, engaging appropriate technical advisers and cooperating with competent authorities.
14. GRIEVANCE REDRESSAL
14.1 Any privacy-related query, request or grievance may be addressed to the Company's designated Grievance Officer or privacy contact at the details set out below:
TRUEFIN CHITS PRIVATE LIMITED
Name: Abhishek M Jain
Designation: Director
Email: support@truefinchits.com
Telephone: +91 – 9655-11-5555
Registered Office: First Floor, No. 43, Medavakkam Tank Road, Kilpauk, Chennai – 600010, Tamil Nadu, India
TrueFIN shall address privacy-related grievances and requests in accordance with the procedure and timelines prescribed under applicable law. TrueFIN shall endeavour to acknowledge such grievances promptly and to resolve them within a reasonable period, and in any event within the timelines prescribed under applicable law.
15. AMENDMENTS TO THIS POLICY
15.1 TrueFIN may amend or update this Policy from time to time to reflect changes in applicable law, regulatory requirements, business practices, technology, services or the manner in which personal data is processed.
15.2 Any revised version of this Policy shall be published on the Website together with an updated “Last Updated” date.
15.3 Where applicable law requires additional notice or consent in relation to a material change to the manner or purpose of processing personal data, TrueFIN shall provide such notice or obtain such consent in the manner prescribed by law.
16. GOVERNING LAW
16.1 This Policy shall be governed by and construed in accordance with the laws of India.
16.2 Nothing contained in this Policy shall exclude, restrict or limit any right, remedy, obligation or liability to the extent that such exclusion, restriction or limitation is prohibited under applicable law.
16.3 In the event of any inconsistency between this Policy and a mandatory requirement of applicable law, the applicable law shall prevail to the extent of such inconsistency.
16.4 This Policy governs the Company's processing of personal data and shall not amend, modify, replace or override the terms of any Chit Agreement or other legally binding contractual document entered into by TrueFIN, unless expressly amended through a legally valid instrument.
CONTACT US
For any questions, concerns or requests relating to this Policy or the Company's processing of personal data, please contact:
TRUEFIN CHITS PRIVATE LIMITED
Registered Office:
First Floor, No. 43, Medavakkam Tank Road, Kilpauk, Chennai – 600010, Tamil Nadu, India
Email: invest@truefinchits.com
Telephone: +91 – 9132-684-684 (Available between 10:00 am – 6:00 pm on all Working days)
Website: www.truefinchits.com
