Fair practices, code of conduct and recovery

Part A — Code of conduct

1. About this code

1.1 Rinncrest Financial Technologies Private Limited ("Rinncrest", "we") operates the Rinn app as a Lending Service Provider for our lending partners, which are NBFCs and banks regulated by the Reserve Bank of India (see our Lending Partners page). "The Lender" means the lending partner that makes your loan. Rinncrest does not lend. It is also the lender's authorised recovery agent for Rinn loans, and carries out reminders, collections and recovery with its own staff (Part B).

1.2 The lender has adopted a Fair Practices Code under RBI's directions to NBFCs Pending confirmation: URL of the Lender's Fair Practices Code.. Because we act for the lender, we are bound by that Code in everything we do on its behalf. This page sets out how we apply it — and the further standards we hold ourselves to — in every interaction with you.

1.3 This code also reflects the RBI (Digital Lending) Directions, 2025, RBI's norms on recovery agents and recovery practices for NBFCs, RBI's directions on outsourcing, the Consumer Protection Act, 2019, the Digital Personal Data Protection Act, 2023, and one of Rinncrest's founding values: borrower dignity in every interaction — at application, during the loan, and if repayments become difficult, whatever the state of the account.

1.4 If this code and the lender's Fair Practices Code ever differ, the standard that protects you more applies.

1.5 This page is a summary for your information. Your loan agreement and Key Fact Statement set out the legal terms of your loan, including any charges for late payment. Not yet published: late payment and bounce charges; until confirmed, refer only to "as shown in your KFS".

2. Definitions

• "You" means anyone who visits our website, uses the Rinn app, applies for or holds a loan through Rinn, or is contacted by us.
• "Staff" means Rinncrest's employees and anyone engaged by Rinncrest to interact with you on its behalf.
• "KFS" means the Key Fact Statement the lender gives you before you accept a loan.
• "EMI" means an equated monthly instalment due under your loan.
• "Overdue" means an EMI, or part of one, not paid by its due date.
• "Recovery agent" means a person authorised in writing by the lender to contact borrowers about overdue amounts on its behalf. For Rinn loans, the lender's authorised recovery agent is Rinncrest, acting only through its own staff.
• "Authorisation letter" means the letter or notice issued by the lender confirming that a named recovery agent may contact you about your loan.
• "Customer in vulnerable circumstances" means anyone who, because of their personal situation — such as illness, bereavement, disability, job loss, age, limited literacy or financial distress — may be especially affected by how we deal with them.

3. Transparency

3.1 The lender is always named. Before you apply and again before you accept, the app tells you that the loan is made by the Lender, and names it.

3.2 Every cost before you commit. The app shows you the lender's KFS — including the interest rate, the Annual Percentage Rate (APR), every charge and the total amount you will repay — before you accept. Nothing that is not in the KFS can be charged without your explicit consent.

3.3 No upfront fees. Rinncrest charges you nothing. No fee is ever collected before disbursal.

3.4 Reasons and documents. If your application is declined, the app tells you. Once a loan is sanctioned, you receive the loan agreement, sanction letter and KFS electronically, and they remain available in the app.

3.5 Changes notified. Changes to the terms of your loan are made only by the lender and notified to you in advance, as the lender's Fair Practices Code requires.

4. Fair and non-discriminatory treatment

4.1 Credit decisions are made only by the lender, on objective criteria in its credit policy. Rinncrest does not make or influence individual credit decisions.

4.2 We do not discriminate on the basis of gender, caste, religion, disability, marital status or any other ground prohibited by law, in how we design the app, present loans, provide service or communicate.

4.3 Rules and models we build to support the lender are documented, tested for unfair outcomes, and reviewed with the lender. Pending confirmation: model-governance and bias-testing process.

5. Honest marketing

5.1 We do not use claims we cannot back. In particular, we never describe a loan as "guaranteed" or "instant", or as "pre-approved" unless a genuine offer from the lender exists; we never promise approval or disbursal times; and we never describe Rinn or Rinncrest as approved, certified or endorsed by RBI.

5.2 Interest is always described as "starting from" a rate, never as a flat rate everyone receives. Illustrative EMIs always say what rate they assume and that your actual rate and APR are in your KFS.

5.3 We do not promote borrowing for speculation, gambling or repaying other loans.

5.4 We do not use designs that push you into a decision — pre-ticked boxes, hidden costs, false countdowns or confusing opt-outs.

5.5 Marketing messages are sent only if you have separately opted in, and you can opt out at any time without any effect on your loan.

6. Communication standards

These standards apply to every contact — service, reminders and recovery alike.

6.1 Language. We communicate in clear, plain English, and in Hindi or Bengali where you ask Pending confirmation: languages supported in-app and by phone.. The KFS is provided in a language you understand, as RBI requires.

6.2 Calling hours. We call or visit only between 8:00 a.m. and 7:00 p.m. your local time, unless you have specifically asked us to contact you outside those hours.

6.3 Frequency. We do not call repeatedly or bombard you with messages, and contact will never be repeated so often that it amounts to harassment. If you tell us a preferred time or channel, we respect it where we can.

6.4 Identity. Our staff always give their name and say they are calling from Rinn, on behalf of the lender. Our emails come only from @rinncrest.in. You can check any contact at Verify it's really us.

6.5 Recording. Calls made to you about your loan, by the lender or by Rinncrest, may be recorded. We tell you at the start of a recorded call. Recordings are kept securely for Pending confirmation: call-recording retention period. and used for quality, training, dispute resolution and regulatory purposes.

6.6 What we never ask for. We will never ask for your OTP, PIN, password or card details, and never ask you to install a screen-sharing or remote-access app.

7. Staff conduct

7.1 Our staff must:

(a) be courteous and patient, and treat you with respect at all times; (b) give accurate information and say so when they don't know; (c) keep your information confidential and discuss your account only with you, or someone you have authorised; (d) never mislead, pressure or rush you into a decision; (e) never use threatening, abusive, obscene or humiliating language; (f) never accept gifts, cash or any payment from you; (g) never ask you to pay anyone other than the lender, through the channels shown in the app; and (h) never give advice or promises about the lender's decisions that they are not authorised to give.

7.2 Every staff member who deals with you — including those who handle reminders, collections and field visits — is trained on this code and the lender's Fair Practices Code when they join and at least once a year. Breaches are investigated and lead to disciplinary action. Pending confirmation: training cadence and disciplinary framework.

8. Privacy and respect for your contacts

8.1 The Rinn app does not access your contacts, SMS, call logs, photo gallery or media files, or the list of apps on your phone. We take location once at application and use the camera only for the KYC selfie.

8.2 We never contact your family, friends, neighbours or colleagues about your loan, and never disclose your loan to them.

8.3 We use your data only for the purposes you have consented to, and never sell it. See our Privacy Policy.

9. Customers in vulnerable circumstances

9.1 If you tell us that something in your life is making it hard to deal with us — illness, bereavement, a disability, losing your job, or anything else — we will:

(a) listen without judgement and record only what is needed to help you, with your consent; (b) give you more time to respond, and adjust how and when we contact you; (c) offer to communicate in another format or language, or with someone you nominate; (d) tell the lender, with your consent, so it can consider what support it may offer; and (e) pause marketing messages to you.

9.2 If you tell us someone is pressuring you to borrow, or using your identity, we will stop the application and help you report it.

9.3 After a borrower's death, we deal with their family sensitively, explain the lender's process, and do not pursue family members for a debt they are not legally responsible for.

Part B — Recovery and collection practices

10. Who carries out recovery

10.1 Recovering overdue amounts is the lender's responsibility. For Rinn loans, the lender has appointed Rinncrest as its authorised recovery agent. Rinncrest carries out reminders, collections and recovery with its own staff, under the lender's Fair Practices Code, RBI's norms on recovery agents and Part A of this code. No outside recovery agency is engaged for Rinn loans.

10.2 This Part explains, in plain language, how the lender and Rinncrest will deal with you if a repayment is missed, and what you are entitled to expect.

11. Before an EMI is due

11.1 The Rinn app shows your repayment schedule. You will receive a reminder before each EMI falls due, by in-app notification, SMS or email. Pending confirmation: reminder schedule and channels.

11.2 Your EMI is collected through the e-mandate you set up in the app, into the lender's account. Make sure your bank account has enough balance on the due date.

11.3 If you know you will have trouble paying, tell us before the due date. We will explain your options and pass your request to the lender.

12. When an EMI is missed — when recovery starts

12.1 If an EMI is not received on its due date, you will be told promptly through the app, SMS or email, with the amount overdue and how to pay it to the lender.

12.2 Late-payment charges, if any, apply only as shown in your KFS. Nothing that is not in your KFS can be charged.

12.3 In the first stage, Rinncrest, on the lender's behalf, will send reminders and may call you to understand what has happened and help you pay.

12.4 If the amount stays overdue, Rinncrest continues recovery on the lender's behalf as its authorised recovery agent, using its own staff, within the limits in clauses 14 to 16.

12.5 Missed payments are reported to credit information companies by the lender (clause 18).

13. Who may contact you, and how you will know they are genuine

13.1 Only these people may contact you about an overdue amount:

(a) the lender's own staff; and (b) Rinncrest staff acting for the lender as its authorised recovery agent, identifying themselves as calling from Rinn.

13.2 You will know who can contact you. The lender names Rinncrest as its authorised recovery agent for your loan in your loan documents at sanction. Rinncrest does not hand Rinn loans to outside recovery agencies. Anyone who claims to be collecting a Rinn loan for any other agency is not authorised; report it to us.

13.3 The lender publishes the recovery agents it has engaged, which for Rinn loans is Rinncrest, on its website. Pending confirmation: URL of the lender's published list.

13.4 Everyone who calls or visits about an overdue amount must, on request:

(a) tell you their name, confirm that they are Rinncrest staff (or the lender's own staff), and confirm they are acting for the Lender; (b) show a photo identity card issued by Rinncrest (or by the lender); and (c) show the lender's authorisation letter or notice for your loan.

13.5 If someone cannot do all of this, or claims to be from any other agency, do not pay them and do not share any information. Check with us in the app or call our Grievance Redressal Officer on +91 82309 07903. See Verify it's really us and Fraud alerts.

14. When and how contact may be made

14.1 The calling hours, frequency and recording rules in clause 6 apply in full to every contact about an overdue amount.

14.2 Place. Contact is made at the address or phone number you have given. If you ask not to be visited at a particular place, such as your workplace, your request will be respected where reasonably possible.

14.3 Inappropriate occasions. Calls and visits will not be made at inappropriate times, such as during a bereavement in the family, a wedding or another major family occasion, or a religious festival you have told us about.

14.4 Privacy. Your loan will be discussed only with you, or with someone you have authorised in writing.

15. What no one acting for the lender may ever do

Neither the lender nor Rinncrest, nor any of their staff, may:

(a) threaten you, verbally or in writing, with violence, arrest, police action, legal action that is not actually intended, or any other harm; (b) use abusive, obscene, insulting or intimidating language; (c) use or threaten physical force, or confine you; (d) contact your family members, friends, neighbours, colleagues or employer to shame you, pressure you or disclose your debt — and the Rinn app never accesses your contacts, so we do not have them; (e) publicly shame or humiliate you in any way — in person, by message, on social media, or by posting your photo or details anywhere; (f) send messages that are anonymous, false or misleading, or that pretend to be from a court, police or government; (g) misrepresent the amount you owe or the consequences of not paying; (h) enter your home or workplace without permission, or remain after being asked to leave; (i) take any of your property without a lawful court process; (j) collect cash, or ask you to pay into a personal bank account, personal UPI ID or QR code; or (k) call or visit outside 8:00 a.m. to 7:00 p.m.

If any of these happens, you have the right to complain (clause 20). If you are in danger, call 112. If you have been defrauded or extorted, call 1930 or report at cybercrime.gov.in (external site).

16. Field visits

16.1 A field visit may be made only by Rinncrest staff acting as the lender's authorised recovery agent. They must carry a Rinncrest identity card and the lender's authorisation (clause 13.4) and show them on request, be polite, keep the conversation private, and leave if asked.

16.2 Staff may not visit in groups intended to intimidate you, and may not speak to neighbours or others about your loan.

16.3 Any visit must be within 8:00 a.m. to 7:00 p.m.

17. Payments, settlements and receipts

17.1 Pay only the lender, through the Rinn app, your e-mandate, or a payment link sent through the app or from the lender's official channels into an account in the lender's name. Pending confirmation: accepted repayment channels for overdue amounts.

17.2 Never pay in cash, and never pay into an individual's account, a personal UPI ID, or a QR code someone shares with you.

17.3 Every payment you make will be reflected in the app and acknowledged by the lender.

17.4 Settlements, waivers and restructuring are valid only if confirmed to you in writing by the lender, on its letterhead or through the app or its official email. A verbal promise by anyone is not a settlement. Do not pay a "settlement amount" unless you have that written confirmation.

17.5 After a loan is closed or settled, the lender issues a no-objection certificate (NOC) or closure letter. See Closing your loan and getting your NOC.

18. Credit reporting

18.1 The lender reports the repayment history of every loan, including missed or late payments and any settlement, to credit information companies, as it is required to under the Credit Information Companies (Regulation) Act, 2005.

18.2 Missed payments can lower your credit score and affect your ability to borrow in future. A loan closed by settlement for less than the full amount is reported as "settled", which lenders may view less favourably than "closed".

18.3 If you think anything reported about your loan is wrong, tell the lender (or us, and we will pass it on). You can also raise a dispute directly with the credit information company. See Your loan and your credit report.

19. If you are facing hardship

19.1 If you miss, or expect to miss, an EMI because your income has fallen, you have lost your job, or you are facing illness, a bereavement or another serious difficulty, please tell us as early as you can — in the app or by phone.

19.2 We will listen, record only what is needed with your consent, adjust how and when we contact you, explain what happens next and pass your request to the lender (clause 9). The lender will consider your situation under its own policies. Any change to your repayments is the lender's decision and is valid only when confirmed in writing.

Complaints and review

20. How to complain

20.1 If we, or anyone contacting you about your loan, fall short of this code, please tell us. Complaining is free and will never affect your application, loan or how you are treated.

20.2 If your complaint is about recovery conduct, complain straight away. Note the date, time, phone number, name given and what was said, and keep screenshots or recordings if you have them. Complaints about recovery conduct are treated as priority complaints.

20.3 Complaints are acknowledged within Pending confirmation (F-51). working days and resolved within 30 days. Full process: Raise a complaint · Grievance Redressal Policy.

20.4 Threats of violence, extortion or impersonation are crimes. Report them to the police (112), the National Cyber Crime helpline 1930 or cybercrime.gov.in (external site) — and tell us.

21. Review

This code is reviewed at least once a year, and whenever the lender's Fair Practices Code, its recovery arrangements or the applicable RBI directions change. The current version and date are shown at the top of this page.

Frequently asked questions

Who will contact me if I miss an EMI?

Only Rinncrest's own staff, calling as Rinn on the lender's behalf, or the lender's own staff. Rinncrest is the lender's authorised recovery agent for Rinn loans and does not use any outside recovery agency.

Can a recovery agent call my family or friends?

No. No one acting for the lender may contact your family, friends, neighbours or colleagues to pressure or shame you, or tell them about your loan. The Rinn app never accesses your contacts.

What time can recovery agents call?

Only between 8:00 a.m. and 7:00 p.m., unless you have asked to be called at another time.

How do I know a recovery agent is genuine?

Your loan documents name Rinncrest as the lender's authorised recovery agent. Anyone who calls or visits must give their name, show a Rinncrest (or lender) photo ID and show the lender's authorisation on request. If they can't, or they say they are from another agency, don't pay — check with us first.

Can I pay a recovery agent in cash?

No. Pay only to the lender through the Rinn app or a link from the lender's official channels. Never pay cash or into a personal account.

Is a settlement offered on the phone valid?

Only if the lender confirms it to you in writing. Don't pay any settlement amount without written confirmation from the lender.

Will a missed EMI affect my credit score?

Yes, it can. The lender reports repayment history, including missed payments, to credit information companies. Paying as soon as you can limits the impact.

Will anyone ask me for a fee to approve my loan?

No. Rinncrest charges you nothing, and no fee is ever collected before disbursal. Anyone asking for one is not acting for us — report it on 1930 or at cybercrime.gov.in (external site), and tell us.

Contact

Rinncrest Financial Technologies Private Limited · CIN U62099WB2026PTC287520 · 2nd Floor, Flat-2, Shivalik, 42, Prince Anwar Shah Road, Tollygunge, Kolkata 700033, West Bengal Grievance Redressal Officer: Bipasa Adhikary · grievance@rinncrest.in · +91 82309 07903 Customer support: in-app Help · support@rinncrest.in · +91 81003 92196

Lender: The Lender for your loan is named in your Key Fact Statement and loan agreement.