Privacy Policy

Effective Date: 20 March 2026

1. Introduction

AVEKA is committed to ensuring that personal information entrusted to it is collected, used, stored, disclosed, and otherwise processed in a lawful, fair, transparent, and secure manner.

AVEKA operates a technology-enabled financing facilitation platform designed to support students, educational institutions, and financing partners through structured financing workflows, including applicant onboarding, eligibility mapping, lender matching, application progression, approval tracking, sanction monitoring, and disbursement visibility.

AVEKA functions solely as a technology and workflow enablement platform. It does not independently undertake lending, underwriting, sanctioning, approval, or disbursement of financial products. All financing determinations are made exclusively by partner lenders, regulated financial institutions, non-banking financial companies, banks, or other funding entities acting in accordance with their own internal credit policies, contractual frameworks, and applicable regulatory obligations.

Where certain operational, technical, administrative, analytics, or support functions are performed by affiliated entities, including Markingo Portal LLC, such processing is undertaken strictly within defined business purposes and subject to appropriate contractual, confidentiality, and data protection safeguards.

AVEKA recognizes that the nature of financing-related personal information requires a heightened standard of accountability, particularly where educational records, identity documentation, financial supporting documents, and cross-border applicant data are involved. Accordingly, personal information is processed only to the extent reasonably necessary for legitimate business purposes and lawful service delivery.

For privacy-related queries, requests, or concerns, users may contact:
Privacy and Data Requests: tech@aveka.ai

2. Scope and Application

This Privacy Policy applies to all personal information processed by AVEKA in connection with:

website access and digital interactions
student financing applications
educational institution onboarding
lender and financing partner engagements
customer support interactions
business communications
platform usage and related service delivery

This Policy applies irrespective of whether personal information is submitted directly by the user, generated through platform interaction, or received through financing ecosystem participants in connection with legitimate service functions.

3. Applicable Legal and Regulatory Framework

AVEKA processes personal information in accordance with applicable data protection and privacy obligations relevant to the jurisdiction of the user, the location of service delivery, the financing relationship, or the operational structure supporting such processing.

Depending on context, this may include compliance obligations arising under:

Digital Personal Data Protection Act, 2023
General Data Protection Regulation
applicable African data protection laws incorporating principles of lawful processing, purpose limitation, proportionality, accountability, and security
legal requirements governing international transfers of personal information
sectoral obligations relevant to financial services, lawful disclosures, fraud prevention, and record retention

Where jurisdiction-specific rights or obligations apply, AVEKA shall give effect to such requirements to the extent legally applicable.

4. Categories of Personal Information Processed

AVEKA processes only those categories of personal information that are reasonably necessary for financing facilitation, platform administration, compliance obligations, fraud prevention, and legitimate operational requirements.

Such categories may include:

full name
date of birth
email address
mobile number
residential address
passport details or government-issued identification where required
academic records, admission documentation, and institutional details
fee invoices and education cost documentation
financial supporting records submitted in connection with financing eligibility
sponsor, guarantor, or co-applicant details where required by financing partners
device identifiers
IP address
browser type and operating system information
usage logs, timestamps, and platform interaction records

AVEKA does not intentionally seek to collect special categories of sensitive personal data beyond what is strictly necessary for financing workflows, regulatory obligations, or applicant-submitted documentation required by financing partners.

Where additional categories of data are required by specific financing partners or jurisdictional obligations, such processing shall remain limited to clearly identified purposes.

5. Purposes of Processing

Personal information is processed solely for identified and legitimate purposes connected with AVEKA’s services, including:

applicant registration and onboarding
financing pathway identification
lender matching and financing facilitation
application workflow administration
communication and user support
fraud detection and misuse prevention
operational analytics and service improvement
audit readiness and compliance administration
lawful record maintenance
transaction-related monitoring and reporting

Where technology-assisted recommendation logic is used to support financing pathway identification, such systems operate only as workflow support mechanisms and do not constitute final financing decision-making.

6. Lawful Basis for Processing

Personal information is processed only where supported by a valid lawful basis under applicable law.

Depending on context, processing may rely upon:

freely given and informed consent
necessity for pre-contractual or contractual performance
compliance with legal and regulatory obligations
legitimate business interests pursued in a proportionate manner that does not override individual rights

Where consent constitutes the legal basis, such consent may be withdrawn prospectively at any time by contacting:
Privacy and Data Requests: tech@aveka.ai

Withdrawal shall not invalidate processing lawfully undertaken prior to withdrawal.

7. Disclosure Within the Financing Ecosystem

Personal information may be disclosed only to the extent reasonably necessary to facilitate legitimate financing workflows or associated compliance requirements.

Recipients may include:

financing partners
banks
NBFCs
regulated lending institutions
educational institutions
technology service providers
communication service providers
analytics vendors
affiliated operational entities

Any disclosure is undertaken under confidentiality obligations, contractual restrictions, and purpose limitations appropriate to the nature of the data shared.

AVEKA does not sell personal information, nor does it authorize unrelated third parties to use personal information for independent commercial exploitation.

8. International Processing and Cross-Border Transfers

Given the cross-border nature of educational financing and institutional engagement, personal information may be processed, accessed, or stored across multiple jurisdictions where operational infrastructure, financing relationships, or service support functions exist, including:

India
United Arab Emirates
South Africa
other jurisdictions connected to applicants, financing institutions, or authorized service providers

Where personal information is transferred internationally, AVEKA adopts reasonable legal, contractual, and technical safeguards designed to preserve equivalent standards of protection.

9. Data Retention

Personal information is retained only for so long as reasonably necessary to fulfil the purposes for which it was collected, including:

financing lifecycle administration
contractual performance
legal and regulatory obligations
audit requirements
dispute management
fraud prevention review

Upon expiry of applicable retention requirements, personal information is securely deleted, anonymized, or archived in accordance with legitimate business needs and legal obligations.

10. Individual Rights

Subject to applicable law, individuals may exercise rights relating to their personal information, including:

access
correction
deletion where legally permissible
restriction of processing
objection to certain categories of processing
portability where applicable
withdrawal of consent where consent is relied upon

Requests may be submitted to:
Privacy and Data Requests: tech@aveka.ai

AVEKA may require reasonable verification before acting on requests in order to protect confidentiality and prevent unauthorized access.

11. Cookies and Digital Technologies

AVEKA uses cookies and similar digital technologies to support:

essential website functionality
security
analytics
service performance monitoring
user experience optimization

Non-essential technologies are deployed only where required consent has been obtained under applicable law.

12. Security and Integrity Measures

AVEKA maintains technical, organizational, and administrative safeguards reasonably designed to protect personal information against unauthorized access, unlawful disclosure, misuse, accidental destruction, or alteration.

Security measures are periodically reviewed in light of operational developments, technological change, and evolving threat environments.

13. Incident Response and Breach Management

Where a personal data incident occurs, AVEKA will assess the nature, scope, and potential impact of the incident and take appropriate containment, remediation, and notification measures where required under applicable law.

14. Children and Age-Sensitive Processing

AVEKA’s services are intended primarily for individuals legally capable of entering financing-related engagements, or applicants acting through lawful guardians where permitted.

AVEKA does not knowingly process children’s personal information contrary to applicable legal requirements.

15. Third-Party Service Providers

AVEKA may engage trusted third-party service providers to support operational, technical, communication, analytics, and hosting functions under appropriate confidentiality and data protection obligations.

16. Policy Review and Amendments

This Privacy Policy explains how AVEKA collects, uses, protects, and handles personal data across its website, digital platforms, and services.

2. Scope of This Policy

This Policy applies to:

Individual applicants (students/parents/guardians) seeking financing facilitation.
Authorized representatives of educational institutions.
Authorized personnel of financing partners and lenders.
General visitors to the AVEKA website and digital interfaces.

3. Nature of AVEKA's Data Role

3.1 Data Intermediary: AVEKA acts as a technology intermediary between applicants, educational institutions, and financing partners. Data collected through the platform is facilitated for the express purpose of processing financing inquiries and maintaining workflow visibility.

3.2 Local Compliance: Data processing is conducted in compliance with applicable regional data protection laws, including but not limited to:

Digital Personal Data Protection Act (DPDP), India.
Protection of Personal Information Act (POPIA), South Africa.
Nigeria Data Protection Regulation (NDPR).
Data Protection Act, Kenya.
General Data Protection Regulation (GDPR) standards (where applicable).

4. Types of Information Collected

AVEKA collects information necessary to facilitate the financing workflow. This may include:

4.1 Personal Identification Information:

Full name, date of birth, nationality, gender, and government-issued identification numbers (e.g., PAN, Aadhaar, NIN, KRA PIN) as required by lenders for KYC purposes.

4.2 Contact Information:

Email address, phone number, and physical residential address.

4.3 Academic Information:

Enrolled institution, course of study, admission status, tuition fee structures, and academic transcripts.

4.4 Financial and Socio-Economic Data:

Income details, employment status, existing financial commitments, and bank account statements provided by the applicant for credit assessment by lenders.

4.5 Technical Data:

IP address, browser type, device identifiers, and platform usage analytics to improve service delivery and security.

5. How Information is Collected

5.1 Directly from You: Through registration forms, document uploads, and platform interactions.

5.2 From Educational Institutions: Information shared by your university to verify enrollment and fee structures.

5.3 From Third-Party Partners: Verified data from KYC providers, credit bureaus, or financial service aggregators with your explicit consent.

6. Purpose of Data Processing

AVEKA processes data for the following specific purposes:

Financing Facilitation: Enabling lenders to assess eligibility and process applications.
Workflow Management: Providing applicants and institutions with visibility into sanction and disbursement status.
KYC and Verification: Meeting regulatory compliance standards for identity and document authentication.
Platform Security: Preventing fraud, unauthorized access, and illicit activity.
Communication: providing updates regarding application progression, system notifications, and support inquiries.

7. Data Sharing and Disclosure

AVEKA does not sell personal data. Information is shared strictly under the following conditions:

With Financing Partners: Shared with banks, NBFCs, or lenders to facilitate credit underwriting and loan processing.
With Educational Institutions: Shared with the relevant university to confirm financing status and coordinate fee disbursements.
With Service Providers: Shared with technology partners (e.g., cloud hosting, KYC verification tools) who operate under strict confidentiality agreements.
Legal Requirements: Disclosed when required by law, court order, or regulatory authorities.

8. Consent Management

By using the AVEKA platform, users provide explicit consent for the collection and processing of their data as outlined in this Policy. Consent may be withdrawn by contacting AVEKA, though this may result in the inability to continue processing financing applications.

9. Cross-Border Data Transfer

As a global infrastructure platform, AVEKA may process or store data in secure cloud servers located outside your home country. In such cases, AVEKA ensures that data transfers are protected by standard contractual clauses and comply with local data residency requirements where mandated.

10. Data Retention

AVEKA retains personal data only for as long as necessary to fulfill the purposes for which it was collected, to comply with legal/audit requirements, or to resolve disputes.

11. Data Security

AVEKA employs industry-standard technical and organizational measures to safeguard data, including encryption in transit and at rest, secure access controls, and regular security audits.

12. Your Rights

Depending on your jurisdiction, you may have the right to:

Access and obtain a copy of your personal data.
Request correction of inaccurate or incomplete information.
Request erasure of data (subject to legal retention requirements).
Object to or restrict data processing.

13. Cookies and Tracking

The AVEKA website uses cookies to enhance user experience and analyze traffic. Users can manage cookie preferences through their browser settings.

14. Updates to This Policy

AVEKA may update this Privacy Policy from time to time to reflect changes in practices or regulatory requirements. Significant updates will be notified through the platform.

15. Contact Information

For inquiries regarding data privacy or to exercise your data rights, please contact the AVEKA Data Protection Officer (DPO) at:

Email: tech@aveka.ai
Subject: Privacy Inquiry